The final deadline for federal agencies to begin submitting all temporary and permanent in electronic format has come and gone. The date set by the Office of Management and Budget (OMB) and the U.S. National Archives and Records Administration (NARA)—June 30, 2024—is now well in the rear-view mirror.
So, does that mean the end of paper in the federal government? Not so fast. Paper is likely to linger for quite some time. If nothing else, analog and physical records will persist in two major forms:
- Analog records that qualify for an exception to M-19-21 and M-23-07: For example, if the records were originally created or received in a format that is not electronic (such as paper, microform, or other analog formats) and converting them to electronic format is not feasible due to technical or resource constraints, agencies may seek an exception. In other cases, certain records are subject to litigation holds or other legal constraints that necessitate maintaining them in their original format. For example, in its 2023 Senior Agency Official for Records Management (SAORM) Annual Report, the Department of Veterans Affairs (VA) noted that certain case files are currently under litigation hold and cannot be digitized.
- Pre-existing legacy records: Existing analog records being stored at the agency or at an authorized Federal Records Center will also continue to exist. While agencies are encouraged to digitize legacy records where feasible, this is not an absolute requirement unless the records are needed for ongoing business purposes and the agency determines that digitization is cost-effective and beneficial. In most cases, agencies will simply follow existing retention schedules for legacy records and, if necessary, continue to store them as-is.
The Need for Hybrid Records Management Solutions
So, while the goal is to transition to electronic records management, federal agencies are not required to immediately digitize absolutely all records, even after June 30, 2024. That means, in many cases, agencies may need to maintain hybrid records management strategies that accommodate both physical and digital records.
A records management platform that supports both allows for more adaptable and future-proofed records management. It will also enable agencies to manage all their records within a single system, providing a holistic view of their records inventory. This integration simplifies management, tracking, and reporting across both record types while also ensuring consistent rules and processes are followed for both types of records.
An ERM equipped with the functionality needed to manage analog records can act like a virtual library where items can be checked in and out by users. In other words, using barcode technology, agencies can continue to track physical records in real-time so they can be quickly located and circulated as needed. This can include individual records, boxes, binders, packages, and more. Ideally, make sure the solution works smoothly with NARA’s own archival and tracking system, ARCIS.
Perhaps more importantly, an integrated system will also make it easier to digitize over time; agencies can gradually digitize and integrate legacy records without disrupting ongoing operations.
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.