Digital Modernization: The Elephant in the M-19-21 Room

Paper is the elephant in the digital modernization room.

As I’ve mentioned in previous posts — 6 Key Worries SAORMs Have About M-19-21 Compliance and SAORM / RMSA Reporting During Social Distancing — I’ve spent a bit of time during the weeks of #socialdistancing reading about digital modernization in some of the SAORM (Senior Agency Official for Records Management) reports that were submitted during the first quarter.

In many agencies there are some truly exciting things going on — efforts to use the M-19-21 deadlines as a vehicle to rethink and modernize their information infrastructures. There is also a theme in many of the reports that most of us on the edges of the IT space don’t like to talk about. It is the elephant in the room when it comes to digital modernization.


Of course, this is not a problem unique to government. Even though the volume of paper-based information is declining over time relative to digital information, there is an incredible long-tail to paper in just about any organization. The paper problem is particularly challenging for government records and IT managers. They are not only charged with the modernization problem; they are also charged with the historical memory problem. And until we get aggressive about paper, many of the most well-intentioned digital business initiatives will face some serious speed bumps.

There are many reasons for the continued pervasiveness of paper. Some are cultural; people just don’t like to change. Some are historical; when paper records were created many years ago, no one thought that they would someday need to be digitized. Some are financial; for many organizations, the M-19-21 requirements are just another unfunded mandate. Some reasons center on the lack of the appropriate skills to address the problem at large scale. Here are a few quotes from the SAORM filings that provide a sampling of the continuing challenges associated with dealing paper at large scale:

“USPTO is challenged with having large volumes of legacy paper files which are still needed for active Agency use.”
— U.S. Patent and Trademark Office

“There are challenges due to a paper-based culture. DoD components use multiple paper-based legacy processes, such as declassification and auditing, that do not yet have an electronic equivalent. Additionally, end-users are often reluctant to stop using their legacy record-keeping systems.”
— Department of Defense

“DOE will need to shift from paper to electronic records, which will require new business processes that provide a complete record lifecycle in electronic form. One challenge DOE has identified is changing employees’ record-keeping habits to favor use of electronic over paper record-keeping practices. Additionally, DOE needs to identify and update business processes that rely on paper record processes (i.e., forms completion and documents currently requiring wet signatures, etc.).”
— Department of Energy

“Those organizations that retain some paper records within their business processes will require greater resources to meet this goal.”
— Bonneville Power Administration

“While staff are engaged and actively working on the transfer of all legacy records to electronic format, the sheer volume and time involved to create and transfer these documents will take all of the allotted time up to 2022.”
— Southwestern Power Administration

“…there is resistance to moving away from paper-based processes.”
— Department of Labor

“…some processes still require physical printing and signing of documents, and work remains to be done to transition such processes to an electronic environment.”
— Alcohol and Tobacco Tax and Trade Bureau

“…the Internal Revenue Code (Code) prohibits the IRS from mandating that taxpayers electronically file (e-file) tax returns, thus taxpayers may file tax returns on paper. The Code only permits the IRS to require e-filing by certain tax return preparers, certain partnerships, and those filing at least 250 returns during a calendar year. The Code also requires the agency to use paper in the conduct of certain business, including the issuance of summonses and notices of deficiency.”
— Internal Revenue Service

“Hard copy records are voluminous and the resources required to meet the goal of fully-electronic record-keeping make the NARA-directed timeframe of 31 December 2022 timeframe untenable and unrealistic.”
— Central Intelligence Agency

“One of EPA’s challenges with fully-electronic record-keeping is changing the culture across the agency. We need to identify and change business processes that currently create paper and provide guidance to fully implement electronic processes…Another challenge is stopping the flow of paper into the Agency coming from the regulated community.”
— Environmental Protection Agency

“While EXIM is well on its way to minimizing creation of any new records in paper form, the most significant challenge to meeting the goal of fully-electronic record-keeping in the near-term is the volume of existing temporary records with a long-term lifecycle that are in paper format. In order to transition to fully-electronic record keeping before the end of the active use or the scheduled post-cut-off preservation term for these records, the records would need to be digitized. Digitization of large volumes of paper records is constrained by the agency’s budgets.”
— Export-Import Bank

“Peace Corps posts are still heavily dependent on paper.”
— Peace Corps

“The decades of permanent records that were created in paper format are a challenge. These records were not required to be transferred to NARA until after 20-30 years and are now all required to be converted to electronic format to meet NARA requirements.”
— Surface Transportation Board

“USAID administers civilian foreign aid and development assistance. As such, the Agency partners with countries that have different statutes, regulations, and policies that do not recognize digital signatures. Collaborating in this capacity leads to the use of paper to document agreements that otherwise would go unrecognized.”
— U.S. Agency for International Development

And that’s just a sampling. All of this means that digitization of paper documents needs to be a strategic priority for every agency. I’ve spent a lot of time during my two decades at AIIM working with both the users and providers of scanning and capture technologies. There used to be such a huge education effort involved in simply explaining the concept of turning paper into digits. That has faded as scanning technology has been consumerized; heck, you can buy a scanner at Best Buy for less than $200.

That’s the good news.  The bad news is that digitization at massive scale and with intelligence attached to each document is not a trivial matter. It’s not the kind of a project that can be turned over to someone’s nephew over summer break. Nor is it a project that should be assigned to internal staff, who already have too much on their plates.

Intelligent capture and digitization is best handled by experts who understand the technology and can scale up without being a distraction from the core mission of the agency. And with the M-19-21 deadlines looming, the time to get serious about the paper elephant in the room is now.

#NARACompliance #M-19-21