a photo of an hourglass The U.S. National Archives and Records Administration (NARA) still expects federal agencies to submit all records in electronic format by December 2022.

But, with the COVID-19 pandemic still ongoing after more than a year, is that goal still achievable?

This is a question we were already asking late last year, but now NARA itself is making the same inquiry. NARA will use recently submitted annual reports from senior records management officials at federal agencies across the U.S. government to determine agency preparedness. “We want to know how confident agencies are, but I think what’s more important is, let’s look at the data and where agencies are, and then see what it is that we can focus on,” said Laurence Chief Records at a Digital Government Institute conference in March according to reporting from the Federal News Network.

Notably, agency expectations always match reality. In prior leaders expressed extreme confidence (greater than 90%) that they were managing records up to NARA standards and were prepared to meet previous electronic submission requirements. However, in fiscal year 2018 at least, only 33% actually transferred all qualifying records to NARA.

Complicating matters, the Office of Management and Budget (OMB) will need to be involved in any decision to extend the deadlines.

“We understand that there have to be some conversations about the 2022 targets, and I expect those conversations will happen — they’re already happening within NARA,” said Brewer. “But we need to have those conversations with OMB as well, since it was a joint memo with OMB, and that has not happened.”

Certainly, the pandemic disrupted the transition to electronic records submissions. Many agencies had to effectively pause work on the project. Employees working from home had less access to paper records, there were fewer resources to handle paper-to-digital conversions, and four of NARA’s Federal Records Centers remain closed even now.

NARA also plans to issue new guidance “soon” for dealing with records relating to social media, web records, and other electronic native record types.

Still, for the time being, the ambitious 2022 deadline remains the goal, so agencies should continue to work on meeting the requirements outlined in Memorandum M-19-21. For agencies concerned about their own state of readiness, the following recommendations can help:

  1. Find an Electronic Records Management platform that can ease the transition. GSA Schedule 36 offers agencies access to approved records management-related vendors and services. Look for ISO-certified organizations.
  2. Specifically, look for solutions that use automation to streamline records management tasks. Ideally, the solution should also offer the ability to manage both physical and electronic records.
  3. Don’t be afraid to ask for help!

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