Five Reasons M-19-21 Readiness Isn’t Business as Usual

I was chatting recently with a senior federal records manager (who will remain nameless) at an FCW seminar about the implications of M-19-21 readiness.

Our initial conversation focused on the immediate short-term deadlines associated with M-19-21 readiness, which are somewhat well known and an extension of the deadlines in the previous 2012 archiving pronouncement, M-12-18 (seriously, some branding around these names would be a good idea). Here are some of the core mandates from M-12-18 (plus a bunch of educational, change management, NARA, and senior agency requirements):

1.1 – By 2019, Federal agencies will manage all permanent electronic records in an electronic format.
1.2 – By 2016, Federal agencies will manage both permanent and temporary email records in an accessible electronic format. (Didn’t quite make that one!)

The additional mandates in M-19-21 readiness are well-known, but for those who “didn’t get the memo,” here they are:

1.1 – By 2019, Federal agencies will manage all permanent electronic records in an electronic format (reaffirming the previous M-12-18 mandate — Nor this one!)
1.2 – By 2022, Federal agencies will manage all permanent records in an electronic format and with appropriate metadata.
1.3 – By 2022, Federal agencies will manage all temporary records in an electronic format or store them in commercial records storage facilities.
1.4 – Federal agencies will maintain robust records management programs that comply with the Federal Records Act and its regulations.

My friend the senior records manager noted that all of this was a pretty significant hill to climb in and of itself, particularly given that there was a notable absence of funding attached to many of the M-12-18 and M-19-21 digitization mandates.

But things got interesting when he started talking about what M-19-21 really meant — when he started talking about what M-19-21 was trying to accomplish with regards to digital government, the stage for information modernization that was being created, and how challenging this task was.

Here are my takeaways from the conversation:

1 — The ultimate goals of M-19-21 are far more foundational than just eliminating paper record submissions to NARA. Consider this passage from M-19-21, and the records digitization mandates it implies:

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.

2 — Despite the requirement in M-12-18 that agencies appoint a Senior Agency Official for Records Management (SAORM), there is still a lack of senior understanding in many agencies about the link between electronic records management and digital government. My records management friend told me, “Good luck getting a meeting with our SAORM. She has so many things on her plate that getting attention for electronic records is pretty low on the list.” For many records management officials, “selling RM” to senior agency officials is still an uphill battle. A modern information management and digitization strategy requires an awareness of where you need to be, where you are, and where you’ve been. This isn’t easy.

3 — Records managers aren’t off the hook either. RM skill sets need to be updated to reflect modern information management requirements. The point of M-19-21 is not just to deal with paper records, but to develop a modern information management and digitization infrastructure than enables Digital Government. RM and governance skills are critical to broader task of information modernization and digital government. Records officers need to think more broadly than just checking off the M-19-21 compliance box.

4 — A true commitment to digital government means ALL information, not just digitizing paper documents and automating e-mail. Many agencies have come a long way in managing traditional forms of information (like documents and emails) in digital form. But per the Federal Records Act (44 U.S.C., § 3301), federal records include “… all traditional forms of records, regardless of physical form or characteristics, including information created, manipulated, communicated, or stored in digital or electronic form.” That means a relook at retention and disposition policies to include texts, social media, data, images, audio, video and a host of other information formats that don’t fit into the easy definitions of a “document.”

5 — Building a framework for incorporation of new technologies is difficult. Many new technologies like Cloud, Robotic Process Automation (RPA), Artificial Intelligence (AI), and Machine Learning offer the opportunity to automate many information governance tasks that are now handled manually. In the process, this could create the cost savings to help fill the funding gap that is at the forefront of M-19-21 readiness concerns. But adopting these technologies at scale is a far different task than viewing a demo at a conference. My contact said there is a critical need for use cases that focus on the practical implementation issues associated with adoption of next generation information governance technologies.

#NARACompliance #M-19-21