If an agency relies on its own expertise for a specific adjudication, must it enter expert opinions into the hearing record?

In administrative adjudication, an agency often has the authority to rely on its own expertise and knowledge in making determinations about complex issues within its purview. When an agency employs its internal expertise, it may draw upon general skills, specialized knowledge, or established procedures that are inherent to its function. This practice allows the agency to process cases efficiently without necessarily being required to provide full documentation of its internal reasoning or expert opinions.

The requirement to enter expert opinions into the hearing record typically pertains to external sources. If the agency relies solely on its internal expertise, there is no obligation to include this internal reasoning as part of the official record, unless required by specific procedural rules or statutes governing the agency. This aspect underscores the autonomy that agencies possess in their adjudicative processes.

While external expert opinions often need to be documented for transparency and accountability, internal advisements or opinions stemming from the agency's expertise can be treated as part of the agency's decision-making process without formal entry into the record. This practice also helps maintain the efficiency of the administrative process by not encumbering the record with extensive internal evaluations that may not be necessary for the adjudication at hand.