After a yearslong process of scrambling to meet a series of increasingly ambitious records management deadlines, federal agencies now find the next major deadline nearly here. It all started back in 2012 with OMB M-12-18, a directive to manage all permanent and temporary emails in an accessible electronic format by the end of 2016. Next, agencies were instructed to manage all permanent records in electronic format by the end of 2019.
Now, OMB M-19-21 mandates that federal agencies manage all permanent records in electronic format with appropriate metadata and manage all temporary records in electronic format (or store them in a commercial records facility) by December 31, 2022.
By now, most federal agencies have been rushing to comply – with mixed results. With the deadline so near, this is a good time to remember some key facts about NARA’s requirements.
1: Even now, it’s not too late.
As the Chinese proverb says: “The best time to plant a tree was 20 years ago. The second-best time is now.” Remember, even if you don’t meet the requirements on M-19-21 on time, agencies must still meet them eventually. Fortunately, there’s a lot you can do to start catching up quickly.
2: If you’re not going to make the deadline, you may qualify for an exemption.
NARA does allow federal agencies to request exceptions and exemptions under certain conditions, especially if the cost is so burdensome it would outweigh the benefit. For more information on how to qualify for an exception and what steps to follow, see here.
3: The right technology is key to this deadline (and will continue to be key to any future mandates).
The era of paper-based records management has passed, full stop. Aside from NARA’s mandates, just keeping up in a digital world full of proliferating records makes a technology-enabled approach to records management a must. If you haven’t invested in a solid electronic records management platform and infrastructure, now’s the time.
4: Remember, making this transition to electronic records management will help NARA and agencies alike.
It may help to remember this isn’t just a “make-work” requirement. NARA is operating under its own mandates to make records more widely accessible and to be more responsive. A government-wide conversion to electronic records is a major plank in its strategy to achieve those goals. Plus, it’s not just NARA that will benefit: individual agencies are likely to see increased efficiencies and cost savings from electronic records management as well.
5: This isn’t the end. Technology doesn’t stand still, nor do the expectations of customers and stakeholders.
Improving records management will continue to be a priority for agencies and the federal government, and that’s not going to stop once this imminent deadline is reached. The march into the future will continue, and agencies need to be prepared to continue updating and implementing their records schedules and plans to account for forward content.
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