Disposition of Federal Records: A Records Management Handbook
2000 Web Edition (of 1997 printed publication)
Records: The Agency's Viewpoint
Records: NARA's Viewpoint
General Records Schedules
- Records are evaluated from the agency's and NARA's viewpoints to determine their final disposition.
- All agency records have value to the agency, but only a small percentage have permanent value.
- Records with temporary value should be identified and scheduled for disposal.
- Records officers should use NARA's guidelines to help identify records with permanent value.
- Records with potentially permanent value should be proposed for scheduled transfer to the National Archives.
- NARA's guidelines for preparing disposition instructions should be followed.
- General Records Schedules (GRS) are NARA-issued schedules governing the disposition of specified series of records common to several or all Federal agencies.
- Normally the GRS authorities are mandatory.
- Since the GRS authorities do not apply to program records, agencies need to submit an SF 115 to NARA for such records.
- Applicable GRS disposition authorities should be included in the agency's records schedule either by interspersing them among authorities derived from SF 115's or by including the entire GRS as part of the schedule or as an appendix.
- Each agency needs to review and, if necessary, update its records schedule at least annually and within 6 months of NARA's issuance of new or revised GRS items for which the agency has no authorized exception.
Once the agency has reviewed its functions and recordkeeping requirements and practices and has inventoried its records, it is ready to evaluate those records and prepare draft disposition instructions. This evaluation and scheduling process, which includes information analysis and decision-making, places all records into one of two categories:
- Temporary: Authorized for disposal immediately or after a specified retention period.
- Permanent: Disposal not authorized. Unless otherwise agreed to by NARA, authorized for transfer to the National Archives.
Agency and NARA Roles
Agencies play an important part in this process by establishing retention periods for nonrecord materials and recommending to NARA retention periods for records. Although NARA is solely responsible for appraising Federal records and approving their final disposition, agency records officers need an understanding of appraisal objectives and standards to prepare and implement schedules.
Appraisal is the process by which NARA evaluates records to determine their final disposition, designating them as either temporary (disposable) or permanent (archival). It is basic to records disposition, which in turn is basic to all of records and information management. The appraisal process is complex and challenging and requires an understanding of:
- The agency's functions, its documentation practices, and its record and information policies, procedures, and systems.
- The importance of records, especially permanent records, in documenting and preserving the memory of an agency, the Federal Government, and American society.
- The role of records disposition, including appraisal, in avoiding both a loss of documentation and too much documentation.
- The agency and NARA perspectives on the value of records.
Records fall into three categoriesthose easy to appraise because they are obviously permanent, those easy to appraise because they are clearly temporary, and those in between that are difficult to appraise. Some records, such as treaties, laws, executive orders, and Supreme Court decisions, obviously have permanent value. Likewise, records of an administrative, or housekeeping, nature clearly have only temporary value and are disposable after a suitable retention period.
Between these two extremes fall many modern program records. Such program records are difficult to appraise because they document diverse agency functions, reflect differing record systems and practices, have various physical forms and characteristics, and contain a broad range of unique information. They require considerable attention in the appraisal and scheduling process.
Guidelines for Evaluating and Scheduling Records
In evaluating and scheduling records for final disposition, it is important to recognize that:
- Records may have permanent value regardless of their physical form or characteristics. The medium may be paper, electronic, audiovisual, microform, or some other, but as records they must be scheduled for an appropriate disposition, which may be permanent.
- The agency may avoid recommending duplicate information for permanent retention by comparing similar records created at different organizational levels. NARA generally designates as permanent only the most complete series of records. In rare instances, two series of records documenting the same activity or containing substantially the same information are designated for permanent retention if they are arranged differently (e.g., chronologically as opposed to alphabetically by subject) and if these different arrangements make them easier to use.
- Because agency programs vary in importance, the number of record series or systems designated as permanent will also vary.
- An agency does not need to evaluate or schedule all its records simultaneously. Instead it may do so incrementally, that is, office by office or function by function, until all its records are covered.
- The NARA appraisal archivist is available for advice and assistance throughout the process.
After completing and verifying the inventory, records managers should examine the inventory for an overview of agency documentation practices. In doing so, it is helpful to bear in mind these three characteristics of Federal agency records:
- Program records are generally more voluminous than administrative, or housekeeping, records.
- Comparatively few records are permanent, although the exact proportion varies from agency to agency and from office to office.
- Case files are generally far more voluminous than all other types of Federal records combined.
In analyzing the records described in the inventory, records managers should focus on the agency's organization, functions, and activities and distinguish between program and administrative records. They should also ensure that all records, regardless of medium, have been identified for the organizational unit or function covered. Sometimes it may be necessary to obtain more information from program and other agency officials before proposing disposition instructions for particular series or systems.
All records have value to the agency creating or receiving them or to oversight or other agencies. A few also have permanent value and warrant preservation by the National Archives once the agency no longer needs them to conduct regular current business. The following sections of this chapter describe the agency's and NARA's perspectives on the value of records.
General Records Schedules
In evaluating its records and preparing disposition instructions, the agency should make proper use of the General Records Schedules (GRS) as it continues to develop a draft comprehensive records schedule. Such a draft schedule is based on records disposition authorities derived from the GRS and one or more approved SF 115's, Request for Records Disposition Authority. This chapter explains how to use the GRS. Chapter V will describe how to complete, clear, and submit an SF 115 and will review the components of a draft records schedule.
Records have value to an agency because:
- They are the basic administrative tool by which the agency conducts its business.
- They document the agency's organization, functions, policies, decisions, procedures, and essential transactions.
- They furnish the information necessary to protect the legal and financial rights of the Government and of persons directly affected by the agency's activities.
Agency record values fall into three overlapping categories: (1) administrative, (2) fiscal, and (3) legal. Understanding these values can help records officers propose to NARA retention periods that will satisfy agency needs.
All records have administrative value because they are necessary to conduct the agency's current business. The duration of this value may be long or short. Some records, such as program directives, have long-term administrative value. Others, such as messenger service files, have short-term administrative value. Many records at operating levels have short-term administrative value because they are correspondence duplicated elsewhere, reports summarized at higher agency levels, or logs serving as temporary controls.
Along with general administrative value, some records may have fiscal value. Records with fiscal value document the agency's financial transactions and obligations. They include budget records, which show how expenditures were planned; voucher or expenditure records, which indicate the purposes for which funds were spent; and accounting records, which classify and summarize agency expenditures. Such agencies as the Office of Management and Budget, the General Accounting Office, the Treasury Department, and the General Services Administration prescribe the form and content of many fiscal records. In most instances, only the data on the forms differ from agency to agency. Consequently the General Records Schedules (GRS) provide disposition authorities for many temporary fiscal records.
Besides administrative and fiscal value, records may also have legal value. Some legal values relate to records that the law requires the Government to create and maintain in the course of its operations. Others, however, are quite broad and do not necessarily involve an agency's operations. Instead they are intended to protect the rights of individuals and organizations. Such records are useful in documenting legally enforceable rights or obligations, both those of the Government and those of persons directly affected by an agency's activities.
Records with legal value contain information that may be used to support rights based on the provisions of statute or regulation. These provisions may be general, such as the statute of limitations on claims or fraud; or they may be specific, such as those providing benefits to persons who have been discharged from the military.
Legal value has long been associated with records documenting such matters as benefits and property ownership. More recently, however, it has also been identified with records documenting environmental and potential health concerns, such as the handling or regulation of chemical and nuclear materials.
Examples of records with legal value include formal decisions and legal opinions; documents containing evidence of actions in particular cases, such as claims papers and legal dockets; and documents involving legal agreements, such as leases, titles, and contracts. They also include records relating to criminal investigations, workers' compensation, exposure to hazardous material, and the issuance of licenses and permits. Still other examples include records relating to loans, subsidies, and grants; entitlement programs such as food stamps and social security; and survivor benefits in Government pension and other programs.
Special concern for legal value applies only to temporary records, because if records are permanent they will always be available to protect legal rights. The GRS designates as temporary many records with legal value, such as those relating to contracts, claims, property disposal, payroll, and civilian personnel.
The duration of legal value varies with the matter at hand. For example, the legal value of contracts and claims records diminishes rapidly after final settlement, and it ends when relevant statutes of limitations expire. Based on statutes of limitation and fraud, other statutory provisions, and practical considerations such as lifespan, records with legal value may be disposable, although they may require a long retention period.
Before recommending retention periods for records that may have legal value, agencies should seek the advice of their general counsel. Factors to be considered in determining retention periods include applicable statutes of limitation, regulatory limits for claims or prosecution, the potential for fraud, and litigation trends involving procedural or substantive rights. They also include particular statutes or regulations granting or limiting a specific legal right as well as the availability of the same information in other record series or systems.
Agencies should retain documentation adequate to establish that they have fully considered legal rights in proposing retention periods for temporary records.
NARA's Appraisal Responsibility
Although agencies recommend retention periods, only NARA can determine and approve final disposition. In carrying out this responsibility, NARA:
- Works with agencies to ensure that retention periods of temporary records are adequate, but not excessive, for agency needs and for the protection of individual rights.
- Makes sure that disposition instructions meet the requirements of other agencies having an interest in certain categories of records; for example, the Office of Personnel Management in civilian personnel records and the General Accounting Office in program and financial records.
- Cooperates with agencies to identify and schedule records having permanent value.
NARA designates records as permanent if they have sufficient historical or other value to warrant their continued preservation by the Government. Such records may be kept mainly because they document an agency's origins, organization, functions, and significant transactions and activities. Or they may be kept mainly because they document the persons, places, things, or matters dealt with by an agency; that is, because they contain information with significant research or reference value.
Appendix C of this handbook contains guidelines that records officers should use to help identify potentially permanent records in terms of their evidential or informational value.
NARA's Use of Sampling and Other Selection Techniques
Although records appraisal normally involves determining the disposition of a series or system as a whole, occasionally NARA selects only individual files from one series for permanent retention. This selection may be qualitative (based on the information content of the files) or quantitative (based on a random or statistical sample). Guideline 14 in appendix C of this handbook contains a list of frequently used selection criteria for case files, and figure 4-2 contains a schedule item involving a selection of permanent records. When recommending such selection, agencies should include the type and the proposed method of accomplishment.
After the records have been evaluated for disposition, the next step is to write recommended cutoffs, retention periods, and other disposition instructions for all records, along with necessary instructions for nonrecord materials.
Although instructions for cutting off records are included in this step, such instructions should be implemented as soon as possible, even if the records are not yet scheduled. This prompt action will avoid unnecessary delays in applying a specific retention period once the agency has received NARA's approval.
Central to preparing disposition instructions is the need to propose specific retention periods for the records that have been inventoried and evaluated. Records with potentially permanent value deserve special attention.
Schedule instructions should be clear, especially those on the final disposition of records. The timing of destruction or transfer to the National Archives must not be left to chance or be subject to possible misinterpretation.
If NARA does not approve the proposed disposition, the agency may include the series or system in its schedule but only with this disposition statement: "Do not destroy. Disposition authorization pending NARA's approval."
Instructions for Permanent Records
If records are proposed as permanent, the disposition instructions need to include these elements:
- The word "Permanent." Use the word "permanent" to designate record series or systems that may have sufficient value to warrant archival preservation by the National Archives. Alternate words, such as "indefinite" or "retain," should not be used. Lengthy retention periods are not equivalent to "permanent."
- Cutoff instructions.
- Instructions for transferring the records to a records center, if applicable. The timing should be based on the length of time after the cutoff, although it may be expressed either as "Transfer ___ years after cutoff" or "Transfer when ___ years old." The particular record center should be specified if it is an exception to the general rule.
- Instructions for transferring the records to the National Archives, including both timing and blocking. The timing should be based on the length of time after the cutoff, although it may be expressed either as "Transfer ___ years after cutoff" or "Transfer when ___ years old." The timing of the transfer should normally be within 30 years for paper records, within 5-10 years for audiovisual or microform records, and as soon as electronic records become inactive or the agency cannot meet maintenance requirements for them. Blocking means the chronological grouping of records consisting of one or more segments of cutoff records that belong to the same series and are dealt with as a unit for purposes of their efficient transfer (e.g., transfer in 5-year blocks). Blocking does not apply to permanent electronic records because they need to be transferred to the National Archives as soon as they become noncurrent or can no longer be maintained properly. If permanent records are to be transferred to a National Archives regional archives, the name of that facility should be specified whenever possible. (See List of Regional Records Services Facilities.)
Figure 4-2 illustrates how to word disposition instructions for records proposed as permanent.
Instructions for Temporary Records
All records not identified as permanent should be scheduled for disposal after a specific retention period. This step is unnecessary if the General Records Schedules already include an appropriate retention period for the records. Recommended retention periods for temporary records are to be based on realistic and informed assessments of their administrative, legal, and fiscal values, as discussed earlier in this chapter.
If records are proposed for destruction, the disposition instructions should contain the term "destroy" (or "delete" if the records are on reusable media, such as magnetic tape or disk). The wording "dispose of" should be avoided because it does not necessarily mean destruction but may include the donation of records as provided for in 36 CFR 1228.
Retention periods for temporary records may be expressed in two ways:
- A fixed period after records in the series or system are created (normally a fixed period after their regular cutoff). For example, the phrase "destroy when 2 years old" provides continuing authority to destroy records in a given series 2 years after their creation (normally 2 years after their regular cutoff).
- A fixed period after a predictable event (normally a fixed period after the systematic cutoff
following that event). The wording in this case depends on the kind of action involved. Note the
- "After completion" (as of a study, project, audit).
- "After sale or transfer" (as of personal or real property).
- "After publication" (as of monthly reports).
- "After superseded" (as of an administrative directive).
- "After revision or cancellation" (as of a form).
- "After acceptance or rejection" (as of an application).
- "After audit" (as of accounts).
- "After settlement" (as of accounts or a claim).
- "After acceptance" (as of a bid or a recommendation).
- "After end of fiscal year" (as of budget reports).
- "After termination" (as of a contract).
- "After transfer" (as of an employee).
- "After conversion to paper or microfilm" (as of information contained in an office automation system).
Other specific wording depends on the nature of the action involved. Some retention periods are based on the likelihood that two different future events may affect a series of records. For example:
- "Destroy when property is sold or vacated, whichever is later."
- "Destroy when superseded by revised plan or when building is sold, whichever is sooner."
Every effort should be made, however, to establish retention periods that are fixed rather than contingent.
The wording of retention periods should be realistic. For example, records should not be scheduled for destruction on termination of the office or program. More often offices or programs are reorganized, or they are incorporated into a second office, or they liquidate so slowly that the precise time of termination becomes a complex legal matter. Instead a different retention approach, such as a fixed time period, should be used.
Likewise, temporary records should not normally be scheduled for destruction "when no longer needed." Since the application of this retention period would vary from person to person, the agency would in effect lose management control of such records, and the agency may inadvertently destroy records that are still needed.
Figure 4-3 illustrates how to word disposition instructions for temporary records.
In evaluating records and preparing disposition instructions, agencies should make proper use of the General Records Schedules (GRS). NARA issues the GRS to provide disposition authority for records common to several or all Federal agencies. The GRS covers records documenting administrative, or housekeeping, functions rather than program functions. Many of these administrative functions are regulated by oversight agencies, such as the Office of Personnel Management (OPM), the General Accounting Office (GAO), and the General Services Administration (GSA). Excluded from GRS coverage are those records maintained by such oversight agencies that relate to their Government-wide management of administrative functions.
Besides many paper-based office files, the GRS covers certain electronic, audiovisual, cartographic, architectural, engineering, and related records. The Index to the General Records Schedules is a list of the current GRS (figure 4-4). Use of the GRS allows records officers to concentrate on scheduling records unique to their agencies.
GRS disposition authorities are legally mandatory (44 U.S.C. 3303a(d)). Agencies must apply the GRS to the greatest extent possible. In practical terms, this means applying the GRS to the types of records specified unless one of two situations exist:
- The agency has already received approval of a shorter retention period in a NARA-approved SF 115. In this situation the agency may apply the shorter retention period unless NARA advises otherwise.
- NARA has approved an SF 115 granting an exception to the GRS-prescribed disposition authority. When submitting the SF 115, the agency must provide written justification for the exception. In deciding whether to request an exception to a GRS authority, the agency follows the same internal clearance procedure used for proposing retention periods for records not covered by the GRS.
If neither situation exists, then it is necessary to apply the new or revised GRS items within 6 months of their issuance by NARA. This action may involve incorporating GRS revisions and additions into the agency records schedule and then distributing the updated portion of that schedule to agency records personnel. Or it may involve distributing the GRS revisions and additions directly to agency records personnel, along with appropriate instructions.
Before using the GRS to determine the disposition of records, an agency should have an overview of the entire process and its component steps, which are listed in figure 4-5 and explained in the remainder of this chapter.
Noting GRS Limitations
Before using the GRS, it is important to read the introduction to each GRS and note any limitations. Such limitations fall into three main categories:
- Record Limitations. Agencies must not attempt to use the GRS for program records. Nor does the GRS necessarily cover all series of administrative records found in agencies. Finally, NARA may grant exceptions to GRS disposition standards when an agency submits an SF 115 along with sufficient written justification.
- Agency Limitations. Some agencies or parts of agencies are excluded from using a particular GRS to schedule their records. For example, GRS 1 (Civilian Personnel Records) does not apply to the program records of the Office of Personnel Management, the Public Health Service's Bureau of Medical Services, the Labor Department's Office of Workers' Compensation Programs, and the Equal Employment Opportunity Commission.
- Date Limitations. Most agency records accumulated before 1921 do not fall under the GRS but must be scheduled by using an SF 115. GRS 3, 11, 16, and 17 have other limiting dates.
Finding GRS Items
The GRS contains three finding aids for users. (1) The table of contents provides a list of GRS titles. (2) The subject index is a list of topics with citations of relevant schedule and item numbers. As in all indexes, it may be necessary to check under more general topics or under synonyms to find the desired subject. (3) The forms index consists of separate lists of standard forms and optional forms referred to in the GRS, along with citations of relevant schedule and item numbers.
Tailoring GRS Items to Fit Agency Records
Records officers must sometimes modify generally-worded GRS items to fit the records of their own agency when adding these items to the agency's records schedule. By drawing on their knowledge of agency functions, records, terminology, and procedures, they can ensure that their tailored descriptions accurately reflect the actual records in their agency's custody. For example, they may insert the name of an organizational unit, include titles of agency forms as illustrations, and reword the series or system title or the description to conform to the agency's normal usage or editorial style. Although the substance of the GRS disposition must remain the same if a definite retention period is specified, appropriate cutoff and retirement instructions may be added.
However, when the GRS disposition authorizes destruction, or deletion, "when no longer needed" for the records, the agency should apply a more specific disposition instruction, such as "Destroy when 1 year old" or Delete after 2 update cycles," which will meet its particular program needs. NARA approval is not needed to establish specific retention periods for records authorized by the GRS for destruction, or deletion, when no longer needed.
Sometimes it might not be readily apparent how the agency will use its records authorized by the GRS for destruction, or deletion, when no longer needed. For example, the Records Disposition Files covered by GRS 16, Item 2a may be used to answer Freedom of Information Act (FOIA) requests or to find out what records may be accretions to those permanent records already accessioned by the National Archives.
All records described in the GRS are scheduled as temporary (that is, disposable or nonpermanent). Usually the GRS authorizes destruction of such records, although occasionally, as in GRS 4, Item 4, it may direct the transfer of records.
A few GRS items have as their disposition cross-references to related records covered elsewhere in the GRS or in agency schedules. In these instances the GRS simply instructs the user to apply the disposition instructions authorized by NARA for the related records.
Giving Special Care to OPM and GAO Records
Several record series are unique because the agency that creates and maintains them does not have full legal control over them. They therefore require special care in their disposition. These series, most of which are covered by the GRS, are:
- Records of the Office of Personnel Management (OPM). The two main
examples of OPM records maintained in agencies are:
- Official Personnel Folders (OPF's). The OPF's document Federal employment for each individual, including service, rights, and benefits. They travel with each employee from agency to agency, beginning with first employment and being closed on separation. If an employee is rehired, the OPF is reopened, and the service continues to be documented until separation. Authorized disposition instructions for OPF's appear in GRS 1, items 1 and 10. >
- The Individual Retirement Record (SF 2806). This shows the amount deducted from pay for the retirement fund. The agency forwards this form, or its equivalent, to OPM when an employee transfers or is separated. The records are not scheduled by the GRS; in fact, GRS 2 specifically excludes coverage of retirement records, such as the SF 2806 or its equivalent. Their disposition is prescribed by a NARA-approved OPM schedule.
- Records of the General Accounting Office (GAO). Since 1950, agency
programs have dealt with records of accountable officers that are held in agency space for GAO audit. These records reflect an audit responsibility GAO has had since its creation in 1921. It is necessary to distinguish the GAO site audit records from agency "memorandum" copies of accountable officers' records. For example,
- GRS 6, item 1a covers the original or ribbon copy of accountable officers' accounts maintained in the agency for site audit by GAO. >
- GRS 6, item 1b covers memorandum copies of accountable officers' returns (with some exceptions).
Title 8 of the "GAO Policy and Procedures Manual for Guidance of Federal Agencies" contains GAO requirements and related program information.
Issuing General Records Schedules Within an Agency
Agencies should include applicable GRS disposition authorities in their comprehensive records schedule, which they should issue and update as a part of a directives system. They generally do so in one of two ways:
- Interspersing the GRS disposition standards item by item among those derived from NARA-approved SF 115's. Taking this approach requires keeping track of the citations of the GRS items dispersed throughout the schedule. Otherwise the agency will be unable to update its comprehensive schedule promptly when NARA issues changes to particular GRS disposition authorities.
- Attaching the entire GRS to the remainder of the comprehensive schedule and updating it promptly when NARA makes additions and changes to the GRS authorities. This approach may require placing cross-references in the non-GRS portion of the schedule to aid the user.
Whichever approach is used, each agency must review and, if necessary, update its records schedule at least annually and within 6 months of NARA's issuance of new or revised GRS items for which the agency has no exception.
Evaluating records and preparing appropriate disposition instructions are essential steps in scheduling records. During this process each agency needs to combine its own disposition instructions for nonrecord materials with records disposition authorities obtained from NARA. These authorities are obtained partly by using the General Records Schedules issued by NARA and partly by submitting to NARA a Standard Form 115, Request for Records Disposition Authority. The GRS disposition authorities are intended primarily for the administrative, or housekeeping, records common to several or all Federal agencies. In contrast, SF 115 disposition authorities are intended primarily for each agency's program records.
After an agency has reviewed its functions and recordkeeping requirements and practices and has inventoried and evaluated the records of an office or function, it is time to use the GRS. Without further NARA approval, records managers should incorporate GRS authorities into the agency's schedule and have them applied to as many administrative records as possible. Proper use of the GRS involves following carefully the instructions given in the GRS, NARA regulations, and this chapter. Any remaining questions should be referred to a NARA appraisal archivist.
For those administrative records not covered by the GRS and for all program records, it is necessary to complete and submit to NARA an SF 115 in accordance with procedures explained in Chapter V. Furthermore, Chapter VI contains general instructions on implementing and updating a comprehensive schedule, whether derived from GRS or SF 115 authorities approved by NARA.
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