M-19-21: Transition to Electronic Records

SUBJECT: Transition to Electronic Records

This Administration is driving transformational change to modernize Government, including moving to electronic government, through multiple complementary channels. In March 2018, the President's Management Agenda (PMA) established an overarching vision to improve mission delivery, customer service, and accountable stewardship on behalf of the American public. The PMA established 14 Cross-Agency Priority (CAP) Goals and recognized that powerful transformation would occur at the intersection of multiple goals, citing the move to an electronic-or "paperless"-government as a primary example that touches multiple goals.

In addition, in June 2018, the Administration's Delivering Government Solutions in the 2 l81 Century: Reform Plan and Reorganization Recommendations included a proposal to transition Federal agencies' business processes and recordkeeping to a fully electronic environment, and end the National Archives and Records Administration's (NARA) acceptance of paper records by December 31, 2022. This memorandum specifically describes the steps the Government will take to meet the NARA goal.

The Federal Government spends hundreds of millions of taxpayer dollars and thousands of hours annually to create, use, and store Federal records in analog (paper and other non-electronic) formats. Maintaining large volumes of analog records requires dedicated resources, management attention, and security investments that should be applied to more effectively managing electronic records. The processes that create analog records increase burden on citizens by requiring them to conduct business with the Government in person or by mail, rather than online, and trap valuable Federal data in paper records where it can only be extracted manually and at great expense.

Agencies are encouraged to consider cost-effective opportunities to transition related business processes to an electronic environment in support of the PMA and Reform Plan. This memorandum specifically focuses on records management, and directs Federal agencies to transition recordkeeping to a fully electronic environment that complies with all records management laws and regulations.

This memorandum directs all Federal agencies to:

• Ensure that all Federal records are created, retained, and managed in electronic formats, with appropriate metadata; and
• Consistent with records management laws and regulations, develop plans to close agency-operated storage facilities for paper and other, analog records, and transfer those records to Federal Records Centers operated by NARA or commercial storage facilities.

Additionally, this memorandum consolidates requirements from prior 0MB records management guidance to ensure consistent, government-wide policy and practices. This consolidation also addresses the burden reduction requirements in 0MB Memorandum M-17-26, Reducing Burden for Federal Agencies by Rescinding and Modifying 0MB Memorandum. Accordingly, 0MB rescinds the following memoranda:

• OMB Memorandum M-12-18, Managing Government Records Directive; and
• OMB Memorandum M-14-16, Guidance on Managing Email.

Section I of this memorandum establishes deadlines for all agencies to adopt electronic recordkeeping requirements, in a manner that complies with the Federal Records Act ( 44 U.S.C. Chapters 29-33). Section II establishes requirements for NARA and the Office of Personnel Management (OPM) that support the government-wide goals in Section I.

Section I: Implementation Guidance for all Agencies

All Federal agencies (CFO Act and non-CFO Act) must meet the following targets in order to begin the transition to a fully electronic government.

1.1 By 2019, Federal agencies will manage all permanent electronic records in an electronic format.

By December 31, 2019, all permanent electronic records in Federal agencies will be managed electronically to the fullest extent possible for eventual transfer and accessioning by NARA in an electronic format. Federal agencies have been required to manage all (permanent and temporary) email records in an electronic format since 2016 and are expected to continue to do so.

1.2 By 2022, Federal agencies will manage all permanent records in an electronic format and with appropriate metadata.

By December 31, 2022, all permanent records in Federal agencies will be managed electronically to the fullest extent possible for eventual transfer and accessioning by NARA in an electronic format. This does not apply to permanent records accessioned into NARA or transferred for storage into Federal Records Centers before December 31, 2022. After December 31, 2022, all agencies will transfer permanent records to NARA in electronic formats and with appropriate metadata, in accordance with NARA regulations and transfer guidance, except where an agency has been granted an exception under procedures to be developed by NARA under paragraph 2.2, below.

1.3 By 2022, Federal agencies will manage all temporary records in an electronic format or store them in commercial records storage facilities.

By December 31, 2022, all temporary records in Federal agencies will be managed electronically to the fullest extent possible. Agencies that receive an exception under paragraph 2.2 may continue to produce and store records in analog formats, but inactive records eligible for transfer after December 31, 2022 must be stored in commercial storage facilities. This does not apply to temporary records that are transferred for temporary storage into Federal Records Centers before December 31, 2022.

By December 31, 2022, all agencies must close agency-operated records storage facilities and transfer inactive, temporary records to Federal Records Centers or commercial records storage facilities. Temporary, analog records that become eligible for transfer after December 31, 2022 must be transferred to commercial storage facilities that meet NARA records storage requirements.

1.4 Federal agencies will maintain robust records management programs that comply with the Federal Records Act and its regulations.

Agencies must continue the following practices to ensure agency records are appropriately retained, stored, and transferred according to their disposition schedules.

• Designate a Senior Agency Official for Records Management who is at the Assistant Secretary level or equivalent and has direct responsibility for ensuring that the agency efficiently and appropriately complies with all applicable records management statutes, regulations, and policy, including the requirements of this memorandum.
• Designate an Agency Records Officer who is responsible for overseeing agency recordkeeping requirements and operations, and holds the NARA Certificate of Federal Records Management Training.
• Annually inform all agency personnel of their records management responsibilities in law, regulation, and policy, and provide training specific to the practices and policies of the organization.
• Ensure all records created or maintained by the agency are covered by a NARA-approved records schedule and permanent records are transferred to the National Archives when they reach their scheduled disposition date
• Ensure NARA-approved records schedules are updated as business practices transition to electronic workflows.

Section II: Implementation Guidance for NARA and OPM

NARA and OPM will take steps to assist all agencies in transitioning to fully electronic records management.

2.1 By 2020, NARA will revise records management regulations and guidance to support Federal agencies' transition to fully electronic recordkeeping.

By September 30, 2020, NARA will issue updated regulations and guidance to provide clear standards for fully electronic recordkeeping, including electronic records storage, formats, and metadata, as well as transfer guidance. NARA will provide modernized processes to efficiently schedule, transfer, and accession permanent, electronic records through fully electronic processes.

NARA will issue updated regulations and clear policies that permit agencies to digitize records created in analog formats and, where appropriate, dispose of analog originals.

In addition, NARA will establish a process to issue exceptions to the provisions of this memorandum where replacing analog records with electronic systems would be burdensome to the public, the cost would exceed the benefit, or otherwise should not be replaced for some other reason, including statutory, regulatory, or policy barriers.

2.3 By 2020, OPM will revise position classification standards for archival and records management occupational series to incorporate electronic records management responsibilities and functions.

By December 31, 2020, OPM will issue updated position classification standards for the archivist, archives technician, and records and information management job series to include electronic records tasks, assignments, and responsibilities.

2.4 By 2022, NARA will no longer accept transfers of permanent or temporary records in analog formats and will accept records only in electronic format and with appropriate metadata.

After December 31, 2022, NARA will no longer accept new transfers of permanent or temporary analog records to the fullest extent possible. NARA will continue to store and service all analog records transferred to a Federal Records Center by that date until their scheduled disposition date. Once those records reach their disposition date, NARA will accept the permanent records into the National Archives in their original (analog) format and will appropriately dispose of the temporary records.

Beginning January I, 2023, all other legal transfers of permanent records must be in electronic format, to the fullest extent possible, regardless of whether the records were originally created in electronic formats. After that date, agencies will be required to digitize permanent records in analog formats before transfer to NARA. Digitization and transfer must be made in accordance with NARA regulations and transfer guidance, including metadata requirements.

published by:
EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503
June 28, 2019 - M-19-21