December 4, 2013
TO: Heads of Federal Agencies
SUBJECT: Guidance on Agency Records Officer Training Requirements
EXPIRATION DATE: December 31, 2015
1. What is the purpose of this Bulletin? (See end note****)
This bulletin provides guidance to assist Federal agency records officers in meeting Requirement 2.3 in the joint Office of Management and Budget (OMB) and National Archives and Records Administration (NARA) Directive M-12-18, Managing Government Records (August 24, 2012).
2. What is required by OMB/NARA Directive M-12-18 for Federal records management training?
OMB/NARA Directive M-12-18 includes requirements for NARA and Federal agencies to reform Government-wide records management policies and practices. Requirement 2.3 of the Directive identifies agency records officers training requirements as follows:
Agency Records Officers Must Obtain NARA Certificate of Federal Records Management Training. By December 31, 2014, the designated Agency Records Officer for each agency must hold the NARA Certificate of Federal Records Management Training. New incumbents must possess the Certificate within one year of assuming the position of Agency Records Officer. Agency Records Officers are generally responsible for overseeing the day to day agency recordkeeping requirements outlined in 36 CFR 1222.22, Subpart B.
3. What is NARA's Certificate of Federal Records Management Training?
NARA operates a national records management training program offering introductory to advanced content in both instructor-led and virtual training environments. Within the training program, NARA awards a Certificate of Federal Records Management Training to individuals who successfully complete Knowledge Area (KA) courses 2 through 6 and then pass the online examinations associated with each course. Upon completion of all courses and examinations, attendees receive the NARA Certificate signed by the Archivist of the United States.
4. Who does this requirement apply to?
This requirement applies to all formally appointed Federal agency records officers. Agency records officers are designated by their agencies in accordance with 36 CFR 1220.34(b). A list of Federal agency records officers is available on NARA’s records management website at: http://www.archives.gov/records-mgmt/agency/.
For those agencies that do not have a named agency records officer listed on the NARA website due to a statutory exemption, the requirement applies to the individual whose name NARA has on file.
5. What agency records management staff are not affected by this requirement?
This requirement does not apply to agency records management personnel who are not the designated agency records officer (e.g., agency program staff or records liaisons).
6. How do Federal agency records officers meet this requirement?
Because of the value of the KA content, particularly when delivered in an instructor-led group environment, NARA encourages all agency records officers to complete the existing KA series for the Certificate. However, to assist agencies in complying with this requirement, NARA has developed a process for granting limited exemptions and exceptions to completing the existing KA series and examinations in their entirety.
7. What is an exemption?
NARA recognizes that some currently-designated agency records officers have years of experience and accreditation in the records management profession. In these cases, NARA is prepared to grant an exemption from obtaining the NARA Certificate. If NARA approves an exemption based on the criteria below, no further action will be required to meet the Directive training requirement.
a. What criteria should be documented in the request for an exemption?
To be considered for an exemption, an agency records officer must meet one of the following criteria before December 31, 2014. These criteria should be referenced and described in the written request to NARA:
i. A combination of Institute of Certified Records Managers (ICRM) certification AND 3 years’ experience as a designated agency records officer;
ii. A combination of Academy of Certified Archivists (ACA) certification AND 3 years’ experience as a designated agency records officer; or
iii. 7 years’ experience as a designated agency records officer at one or more Federal agencies.
b. What is the process for requesting an exemption?
Exemptions must be requested in writing by the Senior Agency Official (SAO); responsible for records management. Requests must be received no later than December 1, 2014. E-mail requests should be sent to NARA’s National Records Management Training Program at NARA.RecordsMgtTraining@nara.gov. Requests by letter should be mailed to:
Office of the Chief Records Officer
National Archives and Records Administration
8601 Adelphi Road
College Park, MD 20740.
The exemption request must indicate the relevant exemption and should include a description of the records officer’s certification and/or experience sufficient for NARA to evaluate the request. In addition, please note that the above criteria must be completed before the agency submits the exemption request.
c. What will NARA do upon receiving a request for an exemption?
NARA will respond in writing to each exemption request within 30 days and, if approved, will indicate that the agency records officer has satisfied Requirement 2.3 of the Directive. NARA will track exempted records officers; however, no Certificate of Federal Records Management Training will be provided. If an agency records officer qualifies for an exemption, but wishes to receive the Certificate, the records officer may choose to follow the procedures below to receive the Certificate through the exception process.
8. What is an exception?
For currently designated agency records officers who do not hold the Certificate of Federal Records Management Training (including individuals designated before December 31, 2014), and also do not meet the criteria above for an exemption, NARA will permit exceptions to the current KA Certificate process to assist agency records officers in meeting Requirement 2.3 before the December 31, 2014 deadline.
a. How does the exception process differ from NARA’s current Certificate process?
Under the exception process, NARA will waive the requirement that records officers must complete the face-to-face KA courses 2 through 6 before taking the examinations. Through this process, NARA will grant the Certificate to records officers who score 75% or higher on each individual KA examination. Upon request, NARA will provide access to the electronic versions of the course materials and the examinations. If a passing score is not obtained after two attempts, the individual will be required to attend that KA and re-take the examination.
b. Are there disadvantages to obtaining the Certificate through the exception process?
Yes. Agency records officers who choose to receive the Certificate by exception rather than attending the instructor-led courses will not have the ability to interact with the instructor(s) and other agency attendees, which is unique to the classroom experience and adds significant value to learning the fundamentals of records management.
c. Do agency records officers need prior approval from NARA before obtaining a Certificate through the exception process?
No. Exception requests do not require approval from NARA, nor do they require a letter from the agency records officer’s SAO. Instead, agency records officers should e-mail NARA’s Records Management Training program at NARA.RecordsMgtTraining@nara.gov to receive information about the course materials and taking the examinations. Additionally, agency records officers who are considered exempt, but who wish to have the Certificate of Federal Records Management Training, may obtain it through the exception process.
9. What is the cost to obtain the Certificate?
The total cost to receive the Certificate by taking the instructor-led courses and passing the examinations is $1,350 per person. Through the exception process, however, NARA will not charge any fees for providing access to the electronic versions of the courses and the examinations.
10. How do agency records officers access the electronic versions of the courses and examinations?
NARA has established a dedicated page within its Learning Management System (LMS) that will contain the electronic versions of the courses and the examinations for eligible agency records officers. Records officers must have a valid username to access the LMS where the content and examinations are maintained. Through the exception process, agency records officers will not receive hard copy notebooks. If you do not have an LMS account, please login to http://nara.learn.com/recordsmanagement-training to create an account using your e-mail address as your username and selecting a password. If you have any questions about accessing the LMS, please contact us at (949) 448-4922, or by e-mail to NARA.RecordsMgtTraining@nara.gov.
11. When should agency records officers expect to receive the Certificate?
After successfully completing KA courses 2 through 6, and receiving a score of 75% or higher on each examination, NARA will issue the Certificate within 6 – 8 weeks. NARA will track the status of all records officers in the LMS, including how the requirements in Requirement 2.3 were met (e.g., through exemption, exception, or instructor-led). At this time, the Certificate does not expire or require “re-certification” once it is awarded.
12. When may agency records officers request an exemption or exception?
The exemption and exception procedures will be in effect through December 31, 2014. Exemption requests must be received by NARA before December 1, 2014. Exception requests must be received by NARA before December 31, 2014. Agency records officers will have one calendar year from the date NARA receives the exception request to obtain the Certificate. For example, if a new agency records officer is appointed in December 2014, and elects to obtain the Certificate by exception, he/she will have until December 31, 2015 to satisfy the requirement. In January 2016, the electronic versions of the course materials and the examinations will no longer be available to agency records officers on the dedicated web page within the LMS.
13. What are NARA's plans for training agency records officers after Requirement 2.3 is met?
Beyond December 2014, NARA will resume its current training procedures. However, NARA is currently developing new and updated course content, both instructor-led and web-based, that will better meet the needs of all Federal records managers. This content will be designed to keep all agency records managers – and other Federal employees -- current on new records management developments, and will be targeted to the various levels and audiences of Federal employees in the Government.
14. Who should agency records officers contact for more information?
For general questions about the OMB/NARA Directive M-12-18 training requirements, including information about exemptions and exceptions, please contact Laurence Brewer, Director, National Records Management Training Program (Acting), at (301) 837-1539, or by e-mail to Laurence.Brewer@nara.gov. For technical or administrative questions related to LMS accounts, or accessing the content or examinations within the LMS, please send an e-mail to NARA.RecordsMgtTraining@nara.gov.
DAVID S. FERRIERO
Archivist of the United States
* Institute of Certified Records Managers. See http://www.icrm.org/.
**Academy of Certified Archivists. See http://www.certifiedarchivists.org/.
***The list of SAOs is available at http://www.archives.gov/records-mgmt/agency/sao-list html.
****NARA bulletins provide fundamental guidance to Federal agencies, who must then determine the most appropriate ways to incorporate recordkeeping requirements into their business processes and identify the specific means by which their agencies will fulfill their responsibilities under the Federal Records Act.