The new reports are in! Records management officials at all federal agencies have submitted their annual Senior Agency Official for Records Management (SAORM) reports to the U.S. National Archives and Records Administration (NARA). It’s clear from the reports that many agencies were still struggling to meet the deadline. For example, the Department of Defense writes, “While many of the DoD Components have taken action to meet the goals of M-19-21, 1. 1 and M-23-07, 1.1 and 1.2, several components identified that they will be unable to do so by June 30, 2024.”
Other agencies that indicated that they would not meet the June 30 deadline include the U.S. Department of Agriculture (USDA), The U.S. Department of the Interior (DOI), the State Department, and others. Remember, however, that even though these reports were submitted this year, they reflect the position of different governmental departments as of the end of 2023 and beginning of 2024. It won’t be clear how many agencies did or did not meet the mid-year deadline until 2025.
What Challenges Are Agencies Continuing to Face in Meeting the Deadline?
Technology Limitations: Some agencies, like the DOD, still need to finalize and validate their execution plans related to the transition to electronic records. Many are still using records management systems that are outdated or do not offer sufficient functionality to meet the demands of the M-19-21 and M-23-07 mandates.
Volume Overwhelm: The sheer volume is proving to be an obstacle in some cases. The Department of Energy (DOE) writes, “Due to the volume of temporary paper records and the lack of available resources, DOE will not meet the requirement.” These high volumes of outstanding records also have budget implications. As the Department of the Interior (DOI) reports: “Not all of remaining records will be digitized, even a fraction of which will cost the Department tens of millions of dollars that is not currently in the budget.”
Lost or Dispersed Records: In some cases, agencies haven’t been able to find all the records they need to digitize. The U.S. Department of Agriculture (USDA), for example, writes “USDA records and information span over 7,500 locations; it will take time to inventory USDA records and information for full compliance, as well as to meet any requirements for a NARA exception to the deadline.”
Other Idiosyncratic Issues: There are also a number of one-off issues. For example, United States Indo-Pacific Command indicates it “will not meet this requirement since the Command Records Manager position has been vacant for a significant period of time.” The Department of Veterans Affairs (VA) states that ongoing litigation is a factor in some records: “VA supports a digital records environment and continues to digitize temporary records for ongoing use in our business process. However, we have a unique legal issue regarding our Veterans Benefits Administration cases files (temporary records that have 35+ year retention) that are currently under litigation hold.”
Are Agencies Making Progress in Shifting to Electronic Records?
Yes! Many indicate that they were on track to meet the June 30 deadline. Even those that weren’t sure about the deadline still note they’ve made significant investments in the infrastructure and processes needed to move to electronic records management. For example, the U.S. Department of Health and Human Services (HHS) Housing and Urban Development (HUD) both expect to meet the deadline, though they note some work remains to be done to fine-tune and improve their records management programs.
Where Do Agencies Still Need Help?
Several agencies used their SAORMs to request further guidance or assistance from NARA. Several asked for clearer guidance on specific record types. For example, the Department of Justice (DOJ) asked for additional guidance on “specific, more practical, and realistically implementable approaches for managing messaging applications, such as text messaging and other forms of electronic messaging, which address the limitations on capture and management that are inherent in these communications tools.”
DOJ also raised a valid point that many agencies are likely to be dealing with more records generated by AI technologies in the future and guidance on handling those records would be helpful.
The VA made one of the most interesting—and perhaps most noteworthy—requests for guidance. They note that many of their citizen stakeholders (veterans and their caretakers) do not have access to electronic devices or internet services, which means the conversion to electronic records management actually makes it harder for that population to access records, not easier. As a result, they have requested that NARA “support and advocate VA’s request to maintain millions of analog records and to keep the VA RCV open until all analog records reached their retention period.”
About PSL
PSL is a global outsource provider whose mission is to provide solutions that facilitate the movement of business-critical information between and among government agencies, business enterprises, and their partners. For more information, please visit or email info@penielsolutions.com.