{"schema_version":1,"research_id":"eoa_inverse_innovation_exp04_external_evaluation_20260802","source_assessment_id":"layer_decay_and_expiration_management__law_governance:PROPOSAL_FIRST:v0","cell_id":"layer_decay_and_expiration_management__law_governance","search_queries":["site:gao.gov outdated agency guidance superseded guidance search administrative guidance","site:archives.gov federal records guidance superseded obsolete records retention disposition legal holds","site:federalregister.gov guidance documents rescinded withdrawn searchable database agency 2020","administrative agency guidance documents outdated superseded current search empirical study","site:acus.gov Public Availability of Inoperative Agency Guidance Documents recommendation 2024","site:acus.gov inoperative agency guidance documents final report 2024 findings agencies websites","site:justice.gov guidance document portal rescinded guidance archive current guidance","site:epa.gov guidance documents archive rescinded replaced guidance portal","site:acus.gov/recommendation \"Public Availability of Inoperative Agency Guidance Documents\"","site:acus.gov \"Recommendation 2022\" \"Inoperative\" guidance documents","site:federalregister.gov \"Public Availability of Inoperative Agency Guidance Documents\" ACUS","site:gao.gov guidance documents agencies outdated rescinded searchable portal","ACUS recommendation 2021 inoperative agency guidance documents adopted final 2021-7","site:acus.gov/recommendation inoperative guidance documents","site:federalregister.gov ACUS inoperative guidance documents recommendation 2022","site:acus.gov/project \"Public Availability of Inoperative Agency Guidance Documents\"","site:acus.gov/recommendation \"priority inoperative guidance documents\"","site:acus.gov \"posted inoperative guidance documents\" \"40%\"","\"Public Availability of Inoperative Agency Guidance Documents\" \"Adopted December 16, 2021\"","\"Administrative Conference Recommendation 2021\" \"Inoperative Guidance\"","\"Public Availability of Inoperative\" \"Federal Register\" guidance","site:learn.microsoft.com purview records management disposition review event based retention labels legal hold official","site:learn.microsoft.com SharePoint document version history restore retention records management official","site:archives.gov digital preservation archive restore testing records readability integrity official guidance","ISO 15489 records management metadata disposition access controls supersession standard","site:opm.gov policy-data-oversight pay-leave salaries-wages 2026 Washington Baltimore Arlington GS table","site:gsa.gov CALC labor rates records management specialist software developer 2026","site:bls.gov occupational employment wages archivists records managers software developers 2025"],"sources":[{"source_id":"S1","title":"Making Inoperative Guidance Accessible to All","publisher":"The Regulatory Review, University of Pennsylvania Program on Regulation","url":"https://www.theregreview.org/2022/05/16/coglianese-rubin-inoperative-guidance-accessible/","source_class":"AUTHORITATIVE_SECONDARY","publication_date":"2022-05-16","accessed_at":"2026-08-02","claims_supported":["The underlying ACUS study examined 19 verified inoperative guidance documents from 10 agencies.","Slightly more than 20% of sampled inoperative documents could not be found online; among those found, about 40% lacked an inoperative label.","Unlabeled obsolete guidance can cause harm when regulated parties or the public rely on outmoded instructions.","Agencies already use watermarks, prominent labels, withdrawn-guidance pages, search tools, and other lifecycle practices."]},{"source_id":"S2","title":"Administrative Conference Recommendation 2021-7: Public Availability of Inoperative Agency Guidance Documents","publisher":"U.S. Government Publishing Office / Administrative Conference of the United States","url":"https://www.govinfo.gov/content/pkg/FR-2022-01-12/pdf/FR-2022-01-12.pdf","source_class":"GOVERNMENT_OR_REGULATOR","publication_date":"2022-01-12","accessed_at":"2026-08-02","claims_supported":["ACUS recommends written procedures for inoperative guidance, explicit status categories, retention duration, searchable organization, unique identifiers, successor links, and prominent status labels.","The recommendation recognizes that supersession can arise from statutory, regulatory, or judicial change even without formal rescission.","Some historical guidance should remain accessible because it documents changes in legal interpretation, policy, reliance interests, and prior agency positions.","Federal Records Act, FOIA, E-Government Act, and OMB guidance create relevant but incomplete publication and preservation obligations.","The recommendation is advisory and accommodates differences in agency capacity."]},{"source_id":"S3","title":"Records Management Guidance","publisher":"U.S. National Archives and Records Administration","url":"https://www.archives.gov/guidance/records-management-guidance","source_class":"OFFICIAL_GUIDANCE","publication_date":"2021-03-11","accessed_at":"2026-08-02","claims_supported":["NARA already operates a searchable and sortable guidance inventory with issue date, status, and status-change date fields.","NARA maintains a distinct superseded or cancelled guidance category.","The Office of the Chief Records Officer has responsibility for guidance on creating, managing, and disposing of federal records."]},{"source_id":"S4","title":"Justice Manual 1-19.000 — Principles for Issuance and Use of Guidance Documents","publisher":"U.S. Department of Justice","url":"https://www.justice.gov/jm/1-19000-limitation-issuance-guidance-documents-1","source_class":"OFFICIAL_GUIDANCE","publication_date":"2022-04","accessed_at":"2026-08-02","claims_supported":["DOJ directs components, whenever practicable, to use its Online Guidance Portal.","DOJ guidance posted to the portal should have unique identifiers and issuance and revision dates.","Guidance does not itself bind the public, but may state agency interpretations and be relevant in litigation.","DOJ is an identifiable adopter with an established governance policy and portal."]},{"source_id":"S5","title":"EPA Guidance Documents","publisher":"U.S. Environmental Protection Agency","url":"https://www.epa.gov/guidance","source_class":"OFFICIAL_ORGANIZATION_DATA","publication_date":"2026-07-14","accessed_at":"2026-08-02","claims_supported":["EPA currently operates an updated portal intended to help users locate active guidance quickly.","EPA excludes guidance superseded by newer guidance from its active portal.","EPA identifies transparency and fair use of guidance as objectives.","EPA is a current, identifiable adopter and possible pilot setting, although regional guidance coverage remained incomplete as of the page date."]},{"source_id":"S6","title":"Disposition of content","publisher":"Microsoft","url":"https://learn.microsoft.com/en-gb/purview/disposition","source_class":"OFFICIAL_PRODUCT_DOCUMENTATION","publication_date":"2025-03-31","accessed_at":"2026-08-02","claims_supported":["Commercial records-management infrastructure already supports retention-triggered human disposition review, role-based permissions, archive disposition, extensions, relabeling, and audit events.","Deletion can be suspended for litigation or audit.","Disposition history and metadata can be shown to reviewers.","Core workflow implementation is available without inventing a new records platform, although guidance-specific semantic and dependency functions are not demonstrated."]},{"source_id":"S7","title":"Digital Preservation Strategy 2022–2026","publisher":"U.S. National Archives and Records Administration","url":"https://www.archives.gov/files/preservation/digital-preservation/digital-preservation-strategy-2022-2026.pdf","source_class":"OFFICIAL_GUIDANCE","publication_date":"2022","accessed_at":"2026-08-02","claims_supported":["NARA treats continued usability, authenticity, accuracy, functionality, persistent identifiers, preservation metadata, and lifecycle logs as preservation requirements.","NARA uses risk-based format assessment, managed repositories, transformations, fixity checking, and annual sample audits.","Preservation and access require ongoing staffing, infrastructure, security, and cross-unit governance.","Archive validation is established practice, though this source specifies fixity and media audits rather than the candidate's full guidance-context restore drill."]},{"source_id":"S8","title":"Salary Table 2026-DCB","publisher":"U.S. Office of Personnel Management","url":"https://piv.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/26Tables/html/DCB.aspx","source_class":"OFFICIAL_ORGANIZATION_DATA","publication_date":"2026-01","accessed_at":"2026-08-02","claims_supported":["Washington-Baltimore-Arlington 2026 base-plus-locality salaries range from $102,415–$133,142 for GS-12, $121,785–$158,322 for GS-13, and $143,913–$187,093 for GS-14.","These rates provide a 2026 labor anchor for resource-equivalent pilot and operations estimates.","The table does not include benefits, contractor premiums, software licenses, storage, security assessment, or agency overhead."]}],"problem_evidence":{"support":"MODERATE","rationale":"The problem is directly visible but prevalence and realized harm remain weakly quantified. A small cross-agency study found that more than 20% of 19 verified inoperative documents were not online and about 40% of the located documents lacked an inoperative label. ACUS formally recognized that guidance becomes inoperative through rescission, supersession, or disuse and that historical versions can remain important. Current DOJ, EPA, and NARA portals show that agencies actively manage identifiers, dates, active status, and superseded material. However, no source measured caseworker error, inconsistent determinations, appeals, or reconstruction failures caused by stale guidance in a specific operational corpus.","source_ids":["S1","S2","S3","S4","S5"]},"stakeholder_evidence":{"support":"STRONG","rationale":"Adopters and authorizers are identifiable. ACUS addressed Recommendation 2021-7 to federal agencies; NARA's Chief Records Officer supplies records-management authority; DOJ formally directs use of a uniquely identified and dated portal; and EPA relaunched an active-guidance portal and states transparency and reliable retrieval objectives. These sources express need for lifecycle governance, although none commits funding for this exact integrated register or its proposed field test.","source_ids":["S2","S3","S4","S5"]},"prior_art":{"proximity":"ESTABLISHED_PRACTICE","closest_analogues":[{"name":"ACUS Recommendation 2021-7 lifecycle for inoperative agency guidance","similarity":"Near-direct policy analogue: written lifecycle procedures, inoperative categories, retention duration, unique IDs, searchable tables, status labels, successor cross-links, and preservation of historically important guidance.","remaining_difference":"It does not require a live inbound-dependency graph, deletion quarantine, archive-restore drills, or a measured historical-date reconstruction outcome.","source_ids":["S1","S2"]},{"name":"NARA searchable guidance portal and federal records lifecycle practice","similarity":"Uses inventory, dates, status, status-change dates, searchable organization, and a separate superseded/cancelled category under an authorized records-management office.","remaining_difference":"The public page does not demonstrate semantic staleness inference, workflow citation dependencies, reversible quarantine, or historical-decision testing.","source_ids":["S3"]},{"name":"DOJ and EPA online guidance portals","similarity":"DOJ prescribes unique identifiers plus issuance/revision dates; EPA maintains an active-only portal that excludes superseded guidance. Both instantiate current-authority retrieval.","remaining_difference":"The cited public implementations do not expose a unified historical lifecycle register, hold/dependency gates, successor-aware tombstones, or restore-test results.","source_ids":["S4","S5"]},{"name":"Microsoft Purview disposition workflow plus NARA digital preservation controls","similarity":"Together they supply retention labels, human disposition review, legal/audit suspension, archival disposition, permissions, audit events, persistent identity, preservation metadata, integrity checks, and risk-based preservation.","remaining_difference":"They are general records and preservation infrastructure, not a guidance-specific semantic staleness and historical-authority system; full contextual restoration and citation-dependency tracing are not established by these sources.","source_ids":["S6","S7"]}],"distinctive_claim_remaining":"For one administrative program, adding an adjudicated dependency graph, point-in-time authority view, and contextual archive-restore drill to an ACUS-style guidance register will improve blinded reviewers' accuracy in identifying guidance operative on a historical decision date by at least 10 percentage points and reduce median retrieval time by at least 25% versus the current portal/document-management-plus-retention process, while missing no known holds and producing no more than 2% false-expiration recommendations. This is a local incremental-effect claim, not a world-novelty claim.","confidence":"HIGH"},"implementation_evidence":{"support":"MODERATE","rationale":"Most primitives are technically and institutionally available: unique identifiers, dated metadata, searchable status fields, retention rules, reviewer roles, legal/audit suspension, audit events, persistent preservation metadata, and integrity sampling. A read-only prototype can therefore be built with bounded risk. The hard parts remain unsolved by the opened sources: identity resolution across copies, semantic staleness detection, complete inbound-reference discovery across informal/external workflows, point-in-time legal interpretation, and restoration of contextual relationships rather than bytes alone. Production disposition would require the guidance owner, records officer, counsel, privacy/security staff, and accessibility/web owners; automated authority changes or deletion would be unsafe.","source_ids":["S2","S3","S4","S6","S7"]},"scores":{"meaningful_impact":{"score":4,"rationale":"Guidance communicates agency legal interpretations and policies; reliance on unlabeled obsolete guidance can mislead affected parties, while historical versions can be necessary to understand prior positions. Realized error and appeal reductions are unmeasured.","source_ids":["S1","S2","S4"]},"stakeholder_pull":{"score":4,"rationale":"ACUS issued a government-wide recommendation, while DOJ, EPA, and NARA operate related portals and governance processes. Exact budget or sponsor commitment for the integrated extension was not found.","source_ids":["S2","S3","S4","S5"]},"incremental_advantage":{"score":2,"rationale":"Most lifecycle-register functions are already recommended or deployed. Incremental value rests on dependency-aware point-in-time reconstruction and tested contextual restoration, whose advantage has not been demonstrated.","source_ids":["S2","S3","S4","S5","S6","S7"]},"distinctiveness_plausibility":{"score":2,"rationale":"The broad proposal substantially collides with established guidance-publication and records-management practice. Only the coupled dependency graph, historical-date evaluation, and contextual restore test remain plausibly distinctive.","source_ids":["S2","S6","S7"]},"technical_implementability":{"score":4,"rationale":"Existing portal, records-management, and preservation systems demonstrate nearly all basic components. Semantic status inference and dependency completeness keep the score below full confidence.","source_ids":["S3","S4","S5","S6","S7"]},"adoption_authority_feasibility":{"score":4,"rationale":"Guidance owners, agency records officers, and counsel are identifiable authorities, and current agency portals prove organizational feasibility. Cross-unit approval and records authority constrain production rollout.","source_ids":["S2","S3","S4","S5"]},"evidence_readiness":{"score":4,"rationale":"A read-only, stratified retrospective comparison can be performed without changing official status or search. It still requires proprietary corpus access and authorized reviewers.","source_ids":["S2","S4","S5"]},"safety_net_benefit":{"score":4,"rationale":"Human review, holds, archive disposition, audit events, preserved metadata, and integrity checks provide credible safeguards against premature deletion and lost history. The candidate's quarantine and contextual restore claims remain untested.","source_ids":["S6","S7"]},"scalability":{"score":3,"rationale":"Common metadata and commercial records tooling support replication, but ACUS explicitly notes variation in agency volume, practices, resources, and capacity. Informal and external dependencies may require substantial local work.","source_ids":["S2","S6","S7"]}},"score_confidence":"MODERATE","costs":{"first_evidence":{"band_2026_usd":"50K_TO_250K","scope":"A 60-day, read-only evaluation of 150 stratified artifacts: corpus extraction, identity/status annotation, two authorized reviewers, records/counsel sampling, comparator timing, dependency checks, and a small restore sample.","confidence":"MODERATE","assumptions":["Approximately 500–1,000 combined analyst, reviewer, counsel, records, and technical hours.","Staff are primarily GS-12 through GS-14 equivalents.","Resource-equivalent cost includes a 1.3–2.0 multiplier over salary for benefits, management, secure workspace, and incidental tooling.","Existing document repositories can be read without a new procurement."],"source_ids":["S8"]},"initial_deployment_startup":{"band_2026_usd":"50K_TO_250K","scope":"Metadata model, authority matrix, retention/hold mapping, limited connector configuration, read-only dashboard, accessibility review, and operating procedures for one corpus after a favorable pilot.","confidence":"LOW","assumptions":["Existing portal or records platform is configurable.","No bulk remediation, public search change, or source-document migration is included.","One records lead, one policy lead, and one technical implementer contribute part-time for three to six months.","Licensing and authorization-to-operate costs are not yet quoted."],"source_ids":["S6","S8"]},"operational_launch":{"band_2026_usd":"250K_TO_1M","scope":"Production launch for one medium agency program, including backfile adjudication, portal/search integration, role and audit configuration, archive workflow, security/privacy/accessibility review, training, rollback controls, and acceptance testing.","confidence":"LOW","assumptions":["One program rather than an enterprise-wide agency rollout.","Roughly two to five staff-years of mixed GS-12–GS-14 or contractor-equivalent effort.","The agency reuses an existing records-management and preservation stack.","Extensive external-link remediation or custom semantic models could move the cost above this band."],"source_ids":["S2","S6","S7","S8"]},"annual_recurring":{"band_2026_usd":"250K_TO_1M","scope":"Ongoing policy-owner reviews, records/counsel oversight, dependency remediation, exception revalidation, portal operations, preservation monitoring, restore drills, training, and support for one program.","confidence":"LOW","assumptions":["Two to four FTE-equivalents across policy, records, legal, and technical roles.","GS-12–GS-14 Washington-area salaries are used as the labor anchor before benefits and operating overhead.","Corpus growth and review volume remain moderate.","Software, cloud, and archive charges are unknown and may materially change the band."],"source_ids":["S7","S8"]}},"verified_pipeline_gates":{"externally_supported_problem":{"status":"YES","reason":"A cross-agency sample found missing and unlabeled inoperative guidance, and ACUS formally recognized the accessibility, status-clarity, and historical-preservation problem. Specific operational harm rates remain unmeasured.","source_ids":["S1","S2"]},"externally_credible_adopter_or_authorizer":{"status":"YES","reason":"NARA, DOJ, and EPA have named institutional roles and active guidance/records portals; ACUS addresses agencies directly with lifecycle recommendations.","source_ids":["S2","S3","S4","S5"]},"distinct_testable_incremental_claim":{"status":"YES","reason":"The residual claim compares dependency-aware, point-in-time, restore-tested review against the existing portal/document-management and retention workflow using accuracy, time, hold, false-expiration, and restore outcomes.","source_ids":["S2","S3","S6","S7"]},"bounded_next_evidence_step":{"status":"YES","reason":"A 150-artifact, 60-day, read-only, randomized crossover review with predefined comparators, metrics, halt conditions, and falsifiers is bounded and does not alter official guidance.","source_ids":["S4","S5","S6"]},"no_unresolved_safety_or_authority_stop":{"status":"YES","reason":"The next step is read-only; official status stays with guidance owners, retention with records officers, and holds with counsel. Any disputed identity, missed hold, unresolved dependency, or current guidance labeled expired triggers a halt. Production deletion remains outside scope.","source_ids":["S2","S3","S4","S6"]},"credible_cost_scope_and_range":{"status":"YES","reason":"All four ranges identify scope and staffing assumptions and use published 2026 federal salaries as a labor anchor. Confidence is only moderate or low because platform licensing, integration complexity, corpus size, and contractor rates are unknown.","source_ids":["S8"]}},"next_evidence_step":"With one agency program and its records officer, counsel, and guidance owner, select 150 artifacts stratified by age, format, issuing unit, and apparent active/superseded status. For 60 days, build a read-only register. Create an adjudicated reference set for operative status on sampled historical dates, successor relations, known holds, preservation constraints, inbound citations, and archive readability. Randomize reviewers in a crossover design between (A) the current portal/document-management-plus-retention process and (B) the register-assisted process; keep reviewers blinded to the study hypothesis and prohibit production labels or search changes. Primary comparisons are historical-date classification accuracy and median retrieval time; secondary comparisons are unresolved citations, reviewer agreement, detected holds, dependency recall against the adjudicated set, and successful contextual restoration across age/format bands. Falsify the incremental claim if accuracy improves by less than 10 percentage points, retrieval time falls by less than 25%, any known hold is missed, false-expiration recommendations exceed 2%, or contextual restore success is below 95%. Halt immediately if a pilot label could conceal current guidance, ownership is disputed, or dependency coverage is materially incomplete.","blocking_evidence":["No agency-specific estimate of stale or ambiguous guidance prevalence has been produced.","No observed baseline links stale guidance to determination errors, appeals, delay, or cost.","Semantic staleness detection accuracy and calibration are unknown.","Complete dependency and hold ground truth is unavailable without proprietary corpus access and authorized review.","The incremental benefit of point-in-time reconstruction and contextual restore testing requires fieldwork; web research cannot establish it.","Platform licensing, integration, security-authorization, accessibility, storage, and contractor costs remain unquoted.","No production authority, budget commitment, or identified pilot sponsor for this exact extension has been verified."],"research_disposition":"KNOWN_PRACTICE_DIFFUSION","world_novelty_boundary":"World novelty, patentability, freedom to operate, market size, and realized impact were not measured. The search establishes that the broad lifecycle-register concept is already recommended and partly implemented. It does not establish whether any system has previously coupled semantic staleness review, complete inbound-dependency gating, point-in-time authority reconstruction, successor-aware tombstones, reversible quarantine, and contextual archive-restore drills exactly as proposed.","arm":"PROPOSAL_FIRST","candidate_version":0,"controller_recommendation":{"action":"STOP_EMPIRICAL_RESEARCH_NEEDED","repairable":true,"material_progress_observed":true,"progress_targets":["Secure a named agency program sponsor and authorized access to one guidance corpus.","Measure corpus-specific prevalence of ambiguous, superseded, orphaned, or unrestorable guidance.","Create an adjudicated point-in-time status, dependency, and hold reference set before testing automation.","Run the predefined current-process versus register-assisted crossover pilot and apply its falsifiers.","Obtain platform, integration, security, accessibility, archive, and recurring operations cost quotes.","If the incremental thresholds fail, treat the work solely as diffusion of ACUS, NARA, and existing records-management practice rather than as a distinct innovation."],"reason":"Bounded web research verified the problem, adopter class, implementation primitives, and a major prior-art collision. The broad intervention is established recommended practice; the only material residual claim concerns the added value of dependency-aware historical reconstruction and contextual restore testing. That claim requires proprietary corpus access, authorized reviewers, and live retrospective testing, so additional web search cannot resolve it."}}