Obtaining Internal Clearances and External Approval
After completing a draft records schedule and before submitting the records schedule to the National Archives and Records Administration (NARA), the records officer needs to obtain clearances from agency program offices and to request GAO's approval, if necessary.
To obtain internal clearances, the records officer should send the completed draft schedule to liaisons in program offices for circulation and comment. Each office should receive only those parts of the schedule relating to its records. Program officials should be asked if:
- All records are covered (Do not include GRS material on the schedules submitted to NARA)
- Descriptions are clear
- Retention periods are adequate
- Cutoff and transfer instructions are clear
- Nonrecord materials are covered (Do not include nonrecord material on the schedules submitted to NARA)
The records officer should also ask for comments on the entire schedule from the agency's historian and, especially for records series or systems that involve legal rights, from the agency's legal office. After all comments are received, any differences should be resolved with program officials or files custodians. These internal clearances are necessary to avoid having to recall the records schedule after it has been sent for approval or having to submit a new records schedule to revise an inappropriate disposition.
The GAO requires that agencies obtain its written approval for records schedule items falling under three general categories:
- Administrative Records Proposed for Retention Periods Shorter Than Those Prescribed by the GRS. GAO has already approved, when necessary, the retention periods of records covered by the GRS. Therefore agencies should not request GAO's approval of retention periods meeting or exceeding GRS standards. They must, however, obtain GAO's written approval when proposing retention periods shorter than those prescribed by the GRS. Agencies should indicate the particular General Records Schedule and item number in requesting GAO approval of a retention period shorter than that found in the GRS.
- All Program Records Having a Proposed Retention Period of Less Than 3 Years. GAO requires the agency to justify fully any such retention period. It neither approves nor disapproves proposed retention periods for program records held 3 years or longer, although it recommends that their retention periods be as short as practicable.
If GAO's approval is necessary, the agency must request it when submitting a records schedule to NARA. While GAO's approval is pending, NARA processes the records schedule but withholds approval until it receives GAO's written concurrence.
Your agency's assigned appraisal archivist can assist you in determining if GAO concurrence is required, and will provide you with GAO contact information.