Obtaining Internal Clearances and External Approval

You may need clearances and approvals before submitting a records schedule to NARA.

Internal Clearances

Program offices should review the draft records schedule that their office will use. Internal clearances help avoid the need to resubmit records schedules.

Questions to ask during internal review:

• Are any records missing? (Other than records covered by a General Records Schedule)
• Are the descriptions clear and accurate?
• Do the retention periods meet business needs?
• Are cutoff and transfer instructions clear and implementable?

Resolve any concerns about the schedule before submission to NARA. NARA staff may ask to meet with program offices during the appraisal process.

Other potential reviewers
Agency Records Officers may also seek internal review from other offices when needed.

• Agency historian
• Information Technology
• Chief Information Office / Chief Data Officer 
• Legal counsel - especially when records involve legal rights

GAO's Approval

Authority: 36 CFR 1225.20

The General Accountability Office (GAO) requires agencies to get their approval when deviating from the GRS for accountable officer records. 

Accountable officer records are covered by GRS 1.1, item 010. NARA will generally not approve deviations to this GRS, however, if GAO concurs, you may request a GRS deviation through the records scheduling process. Documentation of GAO’s concurrence will be required. See Requesting GRS Deviations for more information about that process.

How to request GAO Approval
Send requests for GAO approval to the GAO Records Officer. See the Agency Records Officer Contact List for current contact information.

You will select the status of GAO approval on each item of a proposed records schedule. It is not necessary to have GAO approval at schedule submission, as long as it has been requested. You must receive GAO approval before NARA can approve the schedule.

Contact your agency's assigned NARA appraiser for further help.

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