A photo of stacks of paper with charts on themThe reports are in! Records management officials at federal agencies throughout the U.S. government have submitted their annual Senior Agency Official for Records Management (SAORM) reports to the U.S. National Archives and Records Administration (NARA).

Though NARA is still processing and assessing these reports, they already shed light on a pressing question: how prepared are U.S. government agencies to manage all permanent and temporary records in an electronic format with appropriate metadata by December 31, 2022, under memorandum M-19-21, 1.2?

Off the top, it’s clear that agencies understand that compliance with the mandate requires a multipronged strategy, and they’re implementing initiatives appropriately. The Department of Energy, for example, cites “multiple efforts including targeted training, outreach, direct support to modernize legacy business processes, and working Department wide with records custodians, owners, and IT service providers.”

Most agencies are also working hard to identify and migrate records stored in legacy environments into their new electronic management tools.

But progress appears incremental, increasing the risk that efforts will extend past the 2022 deadline

COVID-19 has clearly slowed agency efforts. Several departments cite the closure of Federal Records Centers and remote working requirements as resulting in serious delays. The Department of Commerce (DOC) says it plainly: “The DOC may experience challenges meeting the deadline of December 31, 2022.”

Some agencies also note that unanswered questions are dogging their efforts. The Department of Housing and Urban Development (HUD), for example, writes:

“Several key services provided by HUD currently must be executed via paper-based processes. It is not yet known if they will be able to be migrated to electronic based tools prior to the deadline. These instances often are related to real estate filings with state or local government agencies.”

Surprisingly, however, the Justice Department appears to be the only agency that has openly asked for an extension, writing:

“First, because of this year of global pandemic and its effect on record keeping for paper records, it would be helpful for NARA to extend the 2022 deadline for moving entirely to electronic recordkeeping.

“As is evident from the information provided in this report, the Department of Justice is moving rapidly toward the management of its electronic content and its electronic records. Nonetheless, because of the pandemic and the resulting interruptions, management of paper records, including simple access to stored content, complications associated with on or off-site handling of paper records for digitization, and adjustments to staffing and resources have and will continue to affect critical projects that are foundational to meet the mandates of M-22-19.”

Many agencies still need key ingredients before they can transition to fully electronic records management

Several agencies said they’re still looking for and evaluating the necessary tools, services, and infrastructure necessary to meet the mandate.

Some of these issues come down to resource availability. The Department of the Interior (DOI) seems to speak for many agencies when it writes, “While the DOI is making good progress in the transition to electronic records, the primary challenge we face is overcoming the resource and budget limitations that will hinder the accomplishment of the 2022 goal.”

In other words, DOI has made good progress – implementing a new cloud-based records management system and transitioning to Microsoft Office 365 – but those efforts alone consumed a lot of the time, budget, and manpower available to them, leaving little left over for remaining tasks.

Funding remains a pivotal, foundational issue

As an unfunded mandate, the new records management requirements are forcing agencies to scramble to find budget for the effort. The Department of Agriculture says, “Identification of funding sources to ensure continued support of the M-19-21 mandates” is a key challenge they’re facing.

Even departments with large budgets are struggling here. The Department of Defense (DOD) has one of the largest budgets of any government agency, and even it writes, “Most prominently, the DoD has insufficient staff resources and funds to properly execute records management programs and meet the goals of the OMB/NARA M-19-21.”

The Department of the Treasury is also another well-funded agency, and it reports:

“Treasury does not currently have sufficient resources to implement fully electronic recordkeeping. Bureaus face significant challenges updating legacy electronic records systems to meet the requirements of M-19-21. Bureaus report that securing dedicated funding for new information technology to support recordkeeping requirements is an ongoing challenge.”

Funding, however, remains only one challenge among many. In our next article in our look at the 2020 SOARM reports, we’ll dive into the specific challenges government agencies name in their submittals.

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