Are M-19-21 Electronic Records Deadlines working for Agencies?

How are Agencies doing in their quest to meet M-19-21 Deadlines? — Three Case Studies

As most records managers in the federal government know, the date 12-31-2022 carries special significance in terms of meeting M-19-21 Electronic Records Deadlines. This is much more than just as a marker for a New Year’s Eve Party. There are two sets of records requirements that make December 31 of next year memorable. Although there is some speculation that these deadlines may shift a bit as a result of COVID, for now they remain in place. So by December 31, 2022, all Federal agencies must:

  1. manage all temporary records in an electronic format.
  2. manage all permanent records in an electronic format with appropriate metadata.

A Check-in on Agencies and the M-19-21 Electronic Records Deadlines

The recently submitted SAORM (Senior Agency Official for Records Management) reports submitted to NARA (full list HERE) provide rich data in understanding the challenges facing agencies in meeting the M-19-21 deadlines. SAORMs act on behalf of the agency head to ensure the agency efficiently and appropriately complies with all applicable records management statutes, regulations, NARA policy, and OMB policy. The SAORM bridges the gap between the agency head and the Records Officer in order to provide strategic direction for the agency’s records management program.

Like many mandatory reports in both the public and private sectors, some agencies do a rather cursory job with their SAORM compliance reports, while others provide rich background on the problems they face and how they are addressing them. I picked three that I found particularly interesting for a deeper dive.

Kudos to the SAORMs at the Department of Justice (Michael H. Allen, Deputy Assistant Attorney General for Policy, Management and Procurement Justice Management Division), the Environmental Protection Agency (Vaughn Noga, Chief Information Officer and Deputy Assistant Administrator for Environmental Information), and the Internal Revenue Service (Celia Y. Doggette, Director, Identity and Records Protection) for taking the time to share their experiences and challenges.

A couple of comments about the three case studies from agencies meeting M-19-21 electronic records deadlines that follow:

  1. In each case, I’ve provided a direct link to the full SAORM report, and if the commentary is of interest, I would urge readers to check out the full reports.
  2. I’ve focused specifically on the requirement for electronic temporary and permanent records; a number of additional topics are also covered in the SAORM reports.
  3. Italics indicate direct quotes from the SAORM reports, although I may have rearranged or shortened them from the original text. Responsibility for any unintentional editing errors or errors in consolidation rest with me.


Department of Justice SAORM report

In terms of the Department’s on site work with paper records, many Components have been unable to conduct or complete inventories of paper records to ensure compliance with Meeting M-19-21 Electronic Records Deadlines in December 2022 deadline and unable to conduct file requests and file returns of paper records due to the closure of the FRCs. In addition to compromising ongoing work and the ability to prepare for digitization and the OMB/NARA M-12-19 deadlines, for some components sending direct offers to the National Archives and declassifying documents that are eligible for transfer to the National Archives has not been available. For those offices that are in the process of moving locations due to construction or change in facility lease agreements, the delay in transferring physical records has resulted in interruptions to space planning and additional operating costs for both personnel and moving/transfers because these records must be transferred to the new location, and then transferred to the FRCs once the FRCs re-open.

In September 2020, the Office of Records Management Policy (ORMP) updated the Department’s RIM Program Strategic Plan (RIM Strategic Plan) to meet the challenges and mandates arising from the evolution of digital information and the issuance of the OMB/NARA M-19-21 RIM Directive. The DOJ RIM Strategic Plan spans 2020-2023 and provides strategies and a work plan to facilitate cross functional, collaborative work among records, business, legal, and technical staffs in the areas of information governance, RIM, technology, training, and measurable evaluation. The Department level RIM Strategic Plan goals are:

  • Governance and Policy: an implemented RIM governance framework that defines authorities, roles, and responsibilities; policies and processes for paper and electronic recordkeeping; and an approach for evaluation and review.
  • Records Management Business Foundations: an implemented RIM business framework and established business rules and practices for recordkeeping of electronic and paper records, as well as digitization.
  • Supporting Technologies: technical tools that address two broad business functional areas related to electronic recordkeeping. These are: 1) systems, services, or applications that electronically capture, create, communicate, or store electronic record information, and 2) technical tools that support high-level management of the RIM Program as a whole.
  • Training: trained DOJ staff and contractors with role-based training for unique roles related to the use and management of Departmental records and basic for all users.
  • Evaluation and Review: defined standards for review and implemented program measurement consistent with controls and data for assessment of program results and improvement.

ORMP, with the Office of the Chief Information Officer (OCIO) established a collaborative team that includes representatives from OCIO, ORMP, and two litigating components of the Department, to develop a strategic management approach for DOJ electronic records. The approach is a governance model that provides for strategic and policy planning, coupled with operational management of electronic records that will
enable the Department to meet legal and mission needs while maximizing resources.

To date, the team has defined electronic records management requirements, reviewed Microsoft 365 recordkeeping capabilities, conducted a market analysis of available tools that integrate with Microsoft 365 for enhanced RIM, and is in the midst of development of a Concept of Operations, requirements validation, and tool recommendations. These efforts will be used to develop M365 and associated tools as a Records Management Service offering for the Department’s components.

ORMP developed guidance for components that outlines a sample project plan and success criteria for meeting the 2022 deadlines. ORMP also provided component-level reports from the previous Department inventories identifying specific records collections that should be reviewed for designated actions (e.g. those with records potentially past disposition, those with records still being created in paper, unscheduled record collections). Additionally, ORMP worked with NARA to identify which old records schedules are still active and are either superseded or obsolete. With that information, ORMP provided each component with a list of its active records schedules requiring review for media neutral revisions to accommodate electronic recordkeeping.

[Note – the Justice submission significantly shortened; make sure to look at the original report!]

Environmental Protection Agency SAORM report

In 2020, the National Records Management Program (NRMP) created a five-year strategic plan to include specific initiatives that will help the agency meet the…stated 1.2 goal in M-19- 21.

The Agency sponsored a working group, under the aegis of its National Records Management Program, that identified different paper processes within the agency that require submission, accumulation, and storage of paper records. The Agency will work to identify the reason why these paper processes exist and, to the fullest extent possible, work with offices to transition their legacy processes to electronic.

EPA has also implemented a National Digitization Program (NDP) and is in the process of standing up two Digitization Centers to digitize EPA long-term temporary and permanent records. EPA has worked closely with OMB and NARA in commenting on the proposed NARA rule for the digitization standards for permanent records.

The Agency requires electronic systems to be registered in the Agency’s Registry of EPA Applications, Models and Data Warehouses (READ), which is the authoritative source of information about EPA electronic information resources. It is a requirement that the appropriate records schedule that applies to each system also be included in READ. READ is reviewed on an ongoing basis to ensure that the records schedules assigned are accurate and that permanent records are transferred to NARA in accordance with the records schedule.

The Agency has implemented a National Digitization Program (NDP) and is in the process of standing up two Digitization Centers to digitize EPA records. NDP has drafted validation instructions and created an SOP and other instructional materials to guide the digitization of temporary records based on NARA’s standards for digitizing temporary records.

EPA has also committed to modernizing and enhancing the Agency’s electronic records management system to manage both permanent and temporary records. This effort includes making the enterprise recordkeeping system more scalable, user-friendly, quickly searchable, accurate, and cost-effective, while also providing better coordinated and effective electronic access to Agency records.

EPA seeks to ensure that all closed/eligible long-term temporary analog records are transferred to the Federal Records Center before December 31, 2022 and [will] estimate the volume of paper records maintained in offices that may require digitization.

Internal Revenue Service SAORM report

The IRS is committed to managing all permanent records in an electronic format.

IRS uses Exchange 2016 Outlook email system to manage email. Retentions are set at the account- level based on IRS’s Capstone approach. All mailboxes of designated Capstone officials are automatically and permanently maintained without burden/dependency on the end-user and will be transferred to NARA in electronic format.

In FY 2020, the IRS completed substantial updates to existing records management policies, procedures, and practices, including management of permanent electronic records and unstructured data.

IRS is leveraging AvePoint Records Manager to ensure all unstructured data, including permanent records, residing in SharePoint Site Collections (or targeted for SharePoint maintenance) and Shared Drives have appropriate retentions and that dispositions are electronically carried out. Additionally, IRS implemented the Documentum records management module to appropriately manage permanent electronic records in that environment.

COVID-19 related challenges further delayed the full deployment and configuration of infrastructure required for management of IRS permanent electronic records, but in December 2020, IRS reported to NARA that the agency successfully completed implementation, and all identified permanent electronic records are appropriately managed. Other initiatives taken to support IRS recordkeeping needs included updated policy and procedural guidance relating to unstructured data, the creation of disposition plans for business unit SharePoint environments, and the implementation of two recordkeeping solutions, AvePoint Records and Documentum Records.

IRS is committed to managing its temporary records in electronic format by December 31, 2022, to the fullest extent possible. The Records Office is actively engaging with IT to procure and develop upgrades to the agency’s SharePoint (unstructured data) environment for greater network-backed records storage, and more automated records retention and destruction controls.

RIM is also in the midst of a comprehensive records control schedule (RCS) update in which electronic records scheduling needs have been identified, most of which are temporary in nature.

RIM staff are fully engaged in systems development life cycle processes and associated digitization/digitalization working groups and committees to ensure agency (electronic) recordkeeping strategies fit a 21st Century framework, and meeting M-19-21 Electronic Records Deadlines.

#NARACompliance #M-19-21