Appraising a Derived-Evidence System
A guide to scheduling systems that manufacture evidence
Some systems hold almost nothing of their own. They draw from systems belonging to other offices and produce a statement about a person that none of those systems contains. Benefits determination, risk scoring, eligibility screening, fraud detection, exposure reconstruction, sanctions matching — all work this way, and all are typically presented for appraisal as an interface or a reporting layer, accompanied by a schedule covering the databases underneath.
That schedule is not wrong so much as aimed at the wrong object.
The method here is jurisdiction-neutral: the layers, the diagnostic questions, and the discipline of testing a claimed authority apply wherever a public body must obtain approval before destroying records. The worked example is drawn from the United States, for two reasons. Its federal recordkeeping regulations happen to state the underlying problem unusually crisply. And the particular system examined is documented in public to a degree that is rare anywhere.
That system is the Individual Longitudinal Exposure Record (ILER), built jointly by the US Department of Defense and Department of Veterans Affairs. It assembles exposure histories for service members, and its output is used to adjudicate disability claims. As of April 2026, according to the Government Accountability Office — the audit body reporting to the US Congress — sixteen Defense and Veterans Affairs databases and registries fed into it, totaling more than 155 million records covering roughly 11.9 million people.
A note on names. NARA, the National Archives and Records Administration, is unusual among national archives in being both the archival institution and the regulator of federal recordkeeping: it writes binding rules, approves every disposal, and appraises what becomes archival. Its regulations sit in Title 36 of the Code of Federal Regulations (36 CFR). Section references below take the form § 1222.22, meaning Part 1222, section 22. Readers elsewhere should substitute their own regulator and instrument; §1a gives a translation table.
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Appraising a Derived-Evidence System is not just an essay. It is a working appraisal tool for systems that assemble existing records, apply rules and relationships, and manufacture a new evidentiary assertion that may affect rights, benefits, eligibility, liability, or other consequential decisions.
The guide gives you a repeatable method to triage the system, map its evidentiary layers, identify what is actually being created, test the disposition authority being claimed, and write a finding that can survive institutional scrutiny. The central question is deceptively simple: has anyone appraised the evidence created by the transformation itself?
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