NARA Bulletin 99-04 B

1. What is the purpose of these instructions?

1. These instructions explain how to schedule the electronic copies of your program records and administrative records not covered by the General Records Schedules (GRS). They supplement NARA regulations, guidance, and other instructions that already exist for scheduling records in general.
   
   
2. Agencies are required by 36 CFR 1228.50(d) to review their approved schedules and, if necessary, update them annually. Agencies are also required by 36 CFR 1228.26(a)(2) to submit schedules for the records of new or reorganized programs within 1 year of the change. This NARA Bulletin 99-04 is separate from these requirements. If series are not currently scheduled, you should develop new schedule submissions to cover both recordkeeping and electronic copies in accordance with NARA Bulletin 98-02.

2. Why can't I continue my present disposition practices?
We are adopting the recommendation from the Electronic Records Work Group Report to the Archivist of the United States that you should schedule the electronic copies of your program records and those administrative records not covered by the GRS. Since the large majority of current agency records disposition schedules do not cover electronic copies, you will need to obtain NARA-approved schedules for them. To comply with this requirement, you must extend existing schedule series items to cover the electronic copies.

3. What definitions apply to this guidance?
See Attachment A for a discussion of "administrative records," "electronic copies," "program records," "recordkeeping copies," "business needs," and other terms used in this guidance.

4. When should I submit revised schedules?
You should submit schedules to cover your electronic copies as soon as possible but no later than February 1, 2000, or in accordance with the plan approved by NARA. We do recognize that agencies differ in terms of how much work is required to complete the task and how many resources are available. For that reason, we offer you a choice to submit either schedules covering the electronic copies of scheduled records or a plan for developing these schedules over a 2-year period or an alternate period approved by NARA in accordance with paragraph 11 of the Bulletin. You must submit either the schedules or a plan for revising your schedules by February 1, 2000.

Preparing Records Schedules

5. How do I revise my previously approved schedules to include electronic copies?
You must ensure through a series-based review that any specific groupings of electronic copies with distinct value in terms of business needs, including both staff and public reference use, are maintained for adequate periods of time. This review may require that you request different retention periods for different series of electronic copies.

6. How should the schedule items be organized?
You may organize the schedule items on a single or multiple SF 115s according to your organizational program, component, or functional area. We developed two scheduling models for you to use as a guide (see Attachments C and D).

7. May I include other unscheduled records?
If you also are scheduling unscheduled records, submit those schedules on separate SF 115s. NARA Bulletin 98-02 provides a model for submitting these schedules.

8. What is the first scheduling model?
Under Model 1 you would add an appropriate disposition for the electronic copies formerly covered by GRS 20, items 13 and 14, to every disposition instruction in your manual or records schedules where the recordkeeping copy has been created with a word processing or e-mail application. You should use Model 1 if:

• You have determined that you have a business need and the technological capability to maintain electronic copies in addition to the paper (or electronic or other format) records that are maintained as the recordkeeping copy; and the electronic copies need to have varying retention periods; and/or
  
  
• You can easily insert a separate disposition statement for the electronic copies for each individual series to which it applies in the agency disposition manual.

9. What is the second scheduling model?
Under Model 2 you would group records by program, function, or organizational component and would propose disposition instructions for the electronic copies associated with each grouping. This format allows you to obtain approval for the disposition without having to physically annotate the disposition for each series of records. To use this model, first determine the most appropriate groupings for your records. If your schedules are organizational, you would most likely group records by organizational component. If you have a functional schedule, you would normally group records by functional area in accordance with the way your schedules or disposition manual are structured. You may propose:

• A single disposition for each grouping with some variation possible (but not required) from group to group (this provides a common disposition for all series within each grouping) or
  
  
• A single disposition for most series within a grouping, but with exceptions to that common disposition identified for specific series.

Regardless of which approach you choose, each proposed disposition should cite either the appropriate agency published disposition manual or the NARA disposition job number(s).

10. How do I submit a revised schedule?
You must submit a complete scheduling package covering electronic copies of program records and administrative records not covered by the GRS. The scheduling package consists of one or more Standard Form 115s (Request for Records Disposition Authority) and a diskette containing electronic versions (in either WordPerfect, MS Word, or Hypertext Markup Language [HTML]) of the SF 115s. Submission of the diskette is not mandatory, but it will enable NARA to process your SF 115(s) sooner. You must also provide adequate cross-references between approved records schedule items or disposition manual citations and the proposed new SF 115 items for electronic copies. Block 6 of the SF 115 requires certification that records proposed for disposal are not needed for agency business after the retention periods specified.

11. Do I need GAO approval of my schedule?
You do not need to obtain GAO approval for SF 115s that include only electronic copies of previously scheduled program and administrative records. Consult with your NARA appraisal archivist on the need for GAO approval if you are also changing the format of the recordkeeping copy to electronic.

12. Can I obtain an electronic SF 115 from NARA?
Contact Jean Cook on 301-837-3570, ext. 238, or e-mail your request to records.mgt@nara.gov to obtain an electronic version of the SF 115. Please specify whether you want WordPerfect 6.0 or MS Word 6 versions.

13. How long will NARA take to review and approve my schedule?

    a. NARA will complete review of schedules in accordance with paragraph 14 of the Bulletin.

    b. To allow us to meet this goal:

• your SF 115 should cover only electronic copies of previously scheduled records, and, where appropriate, changes in the format of the recordkeeping copy (see paragraph 5 of this attachment) and
  
  
• you must respond quickly if we contact you for additional information or clarification.

14. What if I can't revise all my schedules by February 1, 2000?
If you cannot prepare the scheduling package by February 1, 2000, you must submit a plan to us for completion of scheduling within 2 years after NARA approves your plan or within an alternate time period approved by NARA under paragraph 11 of the Bulletin. Plans must provide a coherent strategy for submitting schedules for all electronic copies that lack disposition authority. We will work closely with you to ensure that the plan is realistic and that you are able to demonstrate steady progress in meeting its milestones.

15. What should my plan submission include?

    a. A letter to the NARA Director, Modern Records Programs, from your Chief Information Officer (or other agency official authorized to commit agency resources to carry out the plan) stating that schedules cannot be submitted by February 1, 2000. This letter must include a commitment to schedule your electronic copies in accordance with a plan proposed by you and approved by NARA. Also include the name and telephone number and electronic mail address of your designated agency point of contact for the plan. See Attachment E for an example of a letter.

    b. A plan (see Attachment F) for submitting schedules for all electronic copies. Your plan must include:

• A description of all current agency-issued recordkeeping guidance, including any existing guidance for e-mail and other electronic copies, and the agency's program for training on and implementation of that guidance. NARA regulations for Federal agency records management guidance and implementation may be found under 36 CFR 1220, 1222, 1228, and 1234. Your plan should provide a strategy for bringing about any necessary improvements.
  
  
• A strategy for (1) reviewing your current schedule to determine which series have electronic copies created with word processing or e-mail applications and deciding how long you need to keep them and (2) developing and submitting SF 115s. This strategy must be linked to milestones (see below) and must reflect work necessary to develop schedules for electronic copies.
  
  
• Milestones for taking actions. You should submit SF 115s incrementally throughout the period of the plan. These continuous submissions (covering segments of your activities, e.g., organizational program, component, or functional area) will demonstrate steady progress in scheduling the electronic copies of your scheduled program and non-GRS administrative records.

    c. Please include a diskette containing the electronic version (in either WordPerfect, MS Word, or Hypertext Markup Language [HTML]) of the plan to facilitate NARA review.

16. Should my plan give priority to certain records?
When developing your plan, you should consider business needs to determine which schedules for electronic copies should be developed and submitted first. If you do not have specific internal priorities or if you will request more than two years to complete your scheduling, you should begin with those programs or organizational units that produce records already appraised as permanent in other formats (e.g., paper); records documenting legal and financial rights of individuals and the Government; and records created in high-level offices. (You must commit to scheduling permanent records, legal and financial rights records, and records created in high-level offices in the first 2 years if NARA has approved an alternate period under paragraph 11 of the Bulletin.)

17. What if I am able to revise some but not all of my schedules by February 1, 2000?
You may submit schedules for segments of your electronic copies in conjunction with a plan for scheduling the remainder of your records. In such cases, your plan would describe the submitted schedules as early milestones.

18. What if NARA does not approve my plan?
We will notify you of the plan's deficiencies and work with you to correct those deficiencies in accordance with paragraph 14 of the Bulletin.