Since 2012, the federal government has been pushing agencies to begin managing many records in electronic format. The effort began by focusing on email with OMB Memorandum M-14-16 (“Guidance on Managing Email”) and expanded to other record types with OMB Memorandum M-12-18 (“Managing Government Records Directive”). Since then, agencies have been working towards managing all permanent records in electronic format by the end of this year, with all records submissions to NARA to be in electronic format by the end of 2022.
On June 28, the Office of Management and Budget (OMB) and the National Archives and Records Administration (NARA) issued a new memorandum (OMB/NARA M-19-21) that consolidates, displaces, and expands upon previous guidance related to the government’s transition to electronic records. This new guidance expands upon those previous requirements and implements a number of critical updates.
First, all temporary records must be managed in electronic format alongside permanent records.
Section 1.3 of the new memorandum states, “By December 31, 2022, all temporary records in federal agencies will be managed electronically to the fullest extent possible.” Some exceptions may be available, and this requirement does not apply to temporary records transferred for temporary storage prior to December 31, 2022.
Second, agency-operated storage facilities must close.
The memorandum notes that “the federal government spends hundreds of millions of taxpayer dollars and thousands of hours annually to create, use, and store federal records and analog (paper and other non-electronic) formats.” For this reason, Section 1.3 also mandates that agencies must close any agency-operated records storage facilities. Agencies can use either Federal Records Centers or commercial records storage facilities instead.
Third, NARA will be revising and updating its requirements and policies.
Section 2.1 states, “By September 30, 2020, NARA will issue updated regulations and guidance to provide clear standards for fully electronic record-keeping, including electronic records storage, formats, and metadata, as well as transfer guidance.” Additionally, other aspects of electronic record-keeping requirements will be updated and clarified as well. For example, Section 1.4 clarifies the expectations for federal agencies to maintain robust records management programs, while Section 2.3 establishes that the Office of Personnel Management (OPM) will issue “updated position classification standards for the archivist, archives technician, and records and information management job series.”
What does this mean for federal agencies today?
In some ways, these announcements are good news. Previous guidance has left some questions open, and this and upcomingmemoranda may bring clarity and helpful answers. At the same time, it’s difficult for agencies to prepare for standards that are still being produced. This memorandum reinforces the need to create, adopt, and/or implement tools and processes that are scalable, customizable, and adaptable.
Ultimately, the main point remains the same: the government is committed to a more efficient and less paper-based system of record-keeping. To that end, its efforts will continue to encourage and help federal agencies transition business operations and records management into fully electronic environments.
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