Records Managers

NARA Bulletin 99-04

NOTE: NARA Bulletin 99-04 was suspended on December 27, 1999, by NARA Bulletin 2000-02. The expiration date for Bulletin 99-04 has also been suspended.


March 25, 1999

NARA Bulletin 99-04

TO: Heads of Federal Agencies

SUBJECT: Scheduling electronic copies of program records and administrative records not covered by the General Records Schedules (GRS)

EXPIRATION DATE: March 31, 2001

1. What is the purpose of this bulletin?
This bulletin provides guidance to you on what you must do to schedule electronic copies of your agency's currently scheduled program records and certain administrative records that were previously scheduled under GRS 20, items 13 (word processing documents) and 14 (e-mail).

2. To what records does this bulletin apply?
This bulletin applies only to the electronic copies of scheduled records. The electronic copies covered by this bulletin are the electronic records that were created using word processing or electronic mail software that remain on the "live" computer system after the recordkeeping copy is produced. You may also include in this scheduling effort revisions to schedules for the corresponding recordkeeping copy when you are already converting to electronic recordkeeping.

3. How do I know if I need to schedule electronic copies of my scheduled records?

   a. You need to follow this bulletin and schedule electronic copies if:

     (1) You relied on GRS 20, items 13 and 14, as the disposition authority, or

     (2) Your records schedule states that it is media neutral and the disposition authority applies to copies in all media and formats, unless you have a business need to keep the electronic copies for the same length of time as the recordkeeping copies.

   b. You do not need to reschedule your electronic copies if they are included in a Standard Form (SF) 115, Request for Records Disposition Authority, that has been approved by NARA (or that has been submitted to NARA for approval before the date of this bulletin) that contains specific disposition instructions for both the recordkeeping copies and electronic copies.

     c. If you have questions about which condition applies to your electronic copies, consult the NARA appraisal archivist as discussed in paragraph 15b.

4. What do I do with electronic copies of unscheduled records?
You must schedule electronic copies of unscheduled records and new records series in accordance with NARA Bulletin 98-02.

5. Why is it important to follow the guidance in this bulletin?
The guidance in this bulletin and the deadlines in it have been set to ensure the orderly scheduling of electronic copies previously covered by GRS 20. Under 44 U.S.C. 3105, you must safeguard against the destruction of any agency records that have not been authorized for disposal by the Archivist of the United States in accordance with sections 3301-3314 of title 44. This means that you must request and receive specific disposition authority to delete the electronic copies covered by this bulletin.

6. How does this bulletin relate to the Electronic Records Work Group report and other electronic records issues?

   a. NARA formed an interagency Electronic Records Work Group (ERWG) to identify appropriate areas for revision of the General Records Schedules, explore alternatives for authorizing the disposition of electronic copies of records, and recommend practical solutions for their scheduling and disposition. On September 14, 1998, ERWG submitted its report to NARA. This bulletin reflects the Archivist's decisions on implementing the Work Group's first recommendation that you must schedule your program records and administrative records not covered by the GRS, in all formats.

   b. This bulletin addresses only one of the many issues concerning management of electronic records. The bulletin tells you what you must do to obtain disposition authority for the electronic copy that remains on your computer after you have produced a recordkeeping copy. Although NARA is already working on ways to help agencies develop and implement electronic recordkeeping systems to manage electronic records, this bulletin does not require agencies to implement such systems.

   c. NARA is committed to leading the effort to develop a comprehensive solution to electronic records issues. We will work in partnership with you to ensure steady progress in solving electronic records problems, as promised in the September 21, 1998, statement on the ERWG recommendations. (The statement is available on our GRS 20 web page.)

7. What steps must I take?
Review attachment B to determine whether you can submit records schedules covering all of your electronic copies by February 1, 2000. If you cannot, you must develop and submit a plan by that date that outlines how you will revise your records schedules to cover the electronic copies within a 2-year period after NARA approves your plan, or within an alternate time period approved by NARA under paragraph 11.

8. What if I choose to submit revised schedules?
If you choose to submit revised schedules, you should do so as soon as they are ready, but no later than February 1, 2000. We encourage you to submit revised schedules incrementally as they are completed before this date. Attachment B contains instructions for preparing and submitting revised schedules.

9. Will these revised schedules be available to the public?
Yes. We will publish Federal Register notices on all schedules that you submit to allow interested parties to request a copy of each schedule and any associated appraisal reports from us. The notices will specify which schedules include electronic copies of records being scheduled in accordance with this bulletin.

10. What if I choose to submit a plan for schedule revision?

   a. If you choose to submit a plan for schedule revision, you must do so no later than February 1, 2000. Attachment B contains instructions for preparing and submitting the plan.

   b. You must: (1) identify all the areas that require scheduling; (2) devise an adequate strategy for doing the work required; and (3) outline a logical sequence and schedule for completing the work. We will track your progress in completing the plan through the submission of SF 115s.

11. What should I do if I need more than 2 years to complete the schedule revisions under my plan?
NARA may approve an alternate time period for completing the scheduling effort if you request it and:

   a. You justify in your plan compelling reasons for the additional time, e.g., the size and complexity of the agency and its records.

   b. You commit in your plan to scheduling the electronic copies for the following three categories of records within 2 years:

     (1) Records documenting the legal and financial rights of individuals and the Government;

     (2) Records of high-level offices; and

     (3) All permanent records.

   c. You request in writing an alternate time period at least 30 days before the plan is due. We will evaluate your request for an alternate time period as part of our review of your plan in accordance with paragraph 14.

12. What if I need help preparing schedules or plans?

   a. To assist you in preparing schedules and plans, we will provide no-cost training. Advance registration for these 3-hour sessions is required. Additional training sessions may be arranged at locations outside the Washington, DC, area, as needed. See paragraph 13 for registration procedures.

   b. We have scheduled training sessions for the following dates and locations:

At the National Archives Building
7th and Pennsylvania Ave., DC:
At Archives II
8601 Adelphi Rd., College Park, MD:
April 15 April 22
April 20 May 13
April 21
May 11
May 26

   c. NARA appraisal staff who work with your agency records officer will be available to answer questions during the preparation period, as noted in paragraph 15b.

   d. We will review your submissions and work closely with you to approve your schedules and/or plans.

13. How do I register for training?
Contact Kitty Carter by telephone at 301-713-7100, ext. 221; fax 301-837-3699; or e-mail. Please provide your name, agency, the number of attendees, and a telephone and e-mail address for possible cancellations.

14. How quickly will NARA approve my schedules or plan?

   a. Schedules. We will complete our review of properly submitted SF 115s within the following time limits:

     (1) For schedules that cover only electronic copies, within 180 days if no adverse public comments are received during the Federal Register notice process. If adverse public comments are received, we will complete our review 180 days after the Federal Register comment period ends, or we will consult with you to see if (A) additional time will enable us to resolve outstanding comments or (B) the schedule should be withdrawn at this time for your revision and resubmission at a later date.

     (2) For schedules where your review has identified series where the recordkeeping copy is being maintained electronically or electronic recordkeeping will be implemented within the next 18 months, you may include the change to the recordkeeping copy format in your SF 115. For these schedules, we will complete our review within 330 days after we receive your schedule.

   b. Plans. We will contact you within 45 days after we receive your plan to identify preliminary scheduling steps you may begin to take and confirm the first milestones you should plan to meet. At this time we will also discuss any potential problems and work with you to correct them. We will complete our review of your plan within the following time limits:

     (1) For smaller Executive agencies and individual bureaus or sub-agencies of Departments, no later than 90 days after we receive your plan where the plan is complete and all milestones are proposed for completion within 2 years.

     (2) For entire Departments and large Executive agencies, no later than 120 days after we receive your plan where the plan is complete and either all milestones are proposed for completion within 2 years or the three categories of records (see paragraph 11b) to be scheduled during the first 2 years are clearly identified and covered completely.

     (3) If there are significant problems with the plan or difficult unresolved issues associated with the complexity of the work the plan seeks to accomplish, we will notify you that your plan falls in this category when we make our initial contact within 45 days. At that time we will establish a time frame for you to complete your revisions to the plan and for us to then complete our review, no later than 240 days after we received your initial plan.

   c. Providing information to NARA. Meeting the deadlines proposed in this Bulletin depends on close cooperation between your agency and NARA. You will need to respond quickly to our requests for additional information or clarification so that we can resolve issues in a timely fashion and have your plans and schedules approved within the time frames specified.

15. Who do I contact for further information?

   a. For preparation of plans and schedules address questions to the appraiser in our Life Cycle Management Division with whom your agency normally works.

   b. For general questions and comments concerning this bulletin contact Marie Allen, Director, Life Cycle Management Division, National Archives and Records Administration, 8601 Adelphi Road, Rm. 2200, College Park, MD 20740-6001; or by telephone at 301-837-3570, ext. 224; or by e-mail.

JOHN W. CARLIN
Archivist of the United States


Attachments:

Attachment A - Definitions That Apply to This Bulletin
Attachment B - Instructions for Preparing Records Schedules for Electronic Copies and Plans for Scheduling Electronic Copies
Attachment C - Sample Schedule Using Model 1
Attachment D - Sample Schedule Using Model 2
Attachment E - Sample Cover Letter for Plan
Attachment F - Sample Plan
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