NARA Bulletin 2024-01
[PDF copy]
DATE: September 10, 2024
TO: Heads of Federal Agencies
SUBJECT: Limited Exception for Sending Official Personnel Folders and Employee Medical Folders to the National Personnel Records Center
Expiration Date: Expires on June 30, 2025 for OPFs and June 30, 2027 for EMFs
1. What is the purpose of this Bulletin?
This joint bulletin between the National Archives and Records Administration (NARA) and the Office of Personnel Management (OPM) provides limited exceptions for federal agencies that manage paper or analog Official Personnel Folders (OPFs) and Employee Medical Folders (EMFs). Agencies may continue sending OPFs to NARA’s National Personnel Records Center (NPRC) through June 30, 2025. Agencies may continue sending EMFs to NPRC through June 30, 2027.
2. What are OPFs and EMFs?
The Official Personnel Folder for federal employees, Standard Form 66 (SF-66), contains records for an individual’s federal employment career. Agencies use OPFs to manage federal employee personnel records. (See What is an Official Personnel Folder (OPF)? - OPM.gov)
The Employee Medical Folder, Standard Form 66-D (SF-66D) is a separate file established to contain all the occupational medical records for federal employees. (See 5 CFR § 293.502 - Definitions)
3. How does NARA guidance relate to OPFs and EMFs?
Guidance from the Office of Management and Budget (OMB) and NARA requires agencies to manage their records digitally. This guidance is found in OMB/NARA Memorandum, Update to Transition to Electronic Records (M-23-07) and OMB/NARA Memorandum, Transition to Electronic Records (M-19-21).
The memos state that:
- By June 30, 2024, Federal agencies must manage all temporary records in a digital format or store them in commercial records storage facilities.
- After June 30, 2024, NARA will no longer accept transfers of permanent or temporary records in analog formats and will accept records only in a digital format with appropriate metadata.
The OMB/NARA guidance on transitioning to electronic records management aligns with OPM’s efforts to support the management of electronic OPFs and EMFs.
4. How do agencies use the exception?
To use this exception, agencies must contact the NPRC at civiliantransfer&disposal@nara.gov and provide information about the volume in cubic feet of OPFs and EMFs as well as the projected shipping dates of the records that will be sent to NARA.
Agencies must follow the established OPM procedures for the transfer of personnel records to the NPRC. Records that are not in the correct folders or that are labeled incorrectly will be returned to the agency at their expense. This information is contained in the Guide to Personnel Records, Chapter 7 - Transferring Records.
5. How should agencies transition to digital OPFs and EMFs?
Agencies must transition all OPFs and EMFs to digital records. Agencies may use their own resources or use HR shared service providers. Agencies who are interested in using OPM’s eOPF System may contact the eOPF PMO at eOPFOversightManagers@opm.gov to begin their onboarding process.
OPM guidance for digitizing OPFs and EMFs can be found in the Guide to Personnel Recordkeeping (GPR) and the eOPF Toolkit (VPN connection required. Please log in to your agency's VPN to access this content). NARA’s digitization standards for temporary records are available at 36 CFR 1236 Subpart D.
6. How is OPM supporting agencies transitioning to digital OPFs and EMFs?
OPM is undergoing a modernization process for OPFs and EMFs. They will offer solutions and services to help agencies manage OPFs and EMFs digitally throughout an employee’s federal career and after separation.
The OPM eOPF Program Management Office (PMO) will provide conversion/digitization advisory services and support to agencies after they onboard to the OPM eOPF system.
7. How long are OPFs and EMFs kept?
For OPFs, agencies must follow the disposition instructions in GRS 2.2: Employee Management Records. For long-term OPFs, the GRS 2.2, item 40, mandates a 129-year retention period, or the records can be destroyed sooner when survivor or retirement claims are adjudicated. The short-term records in an OPF are covered by GRS 2.2, item 41, and can be destroyed when superseded, obsolete, or the employee has separated or transferred. Short-term OPF records are not transferred to the NPRC.
EMF disposition is covered under GRS 2.7: Employee Health and Safety Records and may be destroyed 30 years after an employee separates or when the OPF is destroyed.
8. What policy should agencies follow for maintaining and storing OPFs and EMFs?
The GPR provides guidance for the maintenance and storage of OPFs and EMFs, whether in paper or digital format. Title 5 of the Code of Federal Regulations (CFR) 293.307 and 293.510 provides guidance for the transfer of the OPF and EMF between federal agencies and the NPRC.
9. Should agencies send digital OPFs or EMFs to the NPRC?
No, agencies cannot send digital OPFs and EMFs to NARA’s National Personnel Records Center. NARA’s Federal Records Centers Program (FRCP) does not offer storage solutions to maintain digital records. NARA cannot assume responsibility for managing temporary digital records, including cloud storage, migration, and access issues over time.
10. How does this guidance apply to agencies already managing OPFs or EMFs electronically
This bulletin provides an extension to agencies that are still managing OPFs and EMFs in paper formats. If an agency has already made the transition to fully digital OPFs and EMFs, then they should not send paper copies to the NPRC.
11.Will NARA revoke its regulations on OPFs and EMFs?
NARA is removing two regulations:
- 36 CFR 1233.14 What personnel records must be transferred to the National Personnel Records Center?
- 36 CFR 1233.16 How does an agency transfer records to the National Personnel Records Center (NPRC)?
These regulations required agencies to send OPFs and EMFs to the NPRC. However, when agencies and OPM transition to the digital management of OPFs and EMFs, these requirements will no longer be appropriate.
OPM is responsible for issuing guidance on managing OPFs and EMFs. While the NARA regulations will be revoked and no longer in effect, the OPM regulations in 5 CFR Subpart E - Employee Medical File System Records remain in place.
12. Whom should I contact for more information?
For specific questions regarding your agency operations, you should contact your agency’s records officer. A list of agency records officers can be found on the NARA website.
Questions about this policy can be sent to NARA at rmstandards@nara.gov and to OPM at persdoc@opm.gov.
Signed:
DR. COLLEEN J. SHOGAN
Archivist of the United States
ROBERT SHRIVER
Acting Director, U.S. Office of Personnel Management