NARA Appraisal and Approval

Agencies may not dispose of records without approval from the Archivist of the United States. Disposition for many common federal records is available from the General Records Schedules. Agencies must submit a Records Schedule to NARA for all other records.

It usually takes six months or less to process simple schedules. These tend to be schedules for clearly temporary records that do not have legal rights implications. A public comment process makes up roughly two months of this process. It may take up to one year or more for NARA to process large and complex schedules.

To ensure that NARA can process your schedule as quickly as possible:

• Review schedules to make sure that they are well-written with clear information about the content and the use of the records
• Be prepared to answer questions about the records
• Be prepared to schedule appraisal meetings for your appraiser with relevant agency staff

Scheduling and Appraisal Roles

The Agency’s Role

Agencies play an important role in the scheduling and appraisal process. They:

• Identify records to schedule
• Collect information about their records
• Describe record schedule items
• Propose record dispositions
• Recommend retention periods for temporary records
• Explain changes in retention periods for temporary records to the appraiser
• Submit the schedules that start the appraisal process

During the appraisal process, expect to do the following:

• Answer the appraiser’s questions about the records
• Provide more information about the records
• Schedule appraisal meetings with relevant program staff and their NARA appraiser

The Appraiser’s Role

Appraisal is the process by which NARA evaluates records to determine their final disposition. We identify records as either temporary (disposable) or permanent (archival).

The appraisal process can be complex and challenging. It requires an understanding of:

• The agency’s functions
• The agencies practices, policies, and procedures
• The importance of records in documenting the actions of the federal government, or the value of records as evidence
• The importance of records in documenting historical memory and American society, or the value of records as information

NARA cannot preserve all records created by the federal government. We must be selective in what we appraise as permanent. The role of appraisal is to:

1. Ensure that important records are identified and preserved. 
2. Avoid the unnecessary maintenance of too much documentation. 

Our appraisal criteria for permanent records is described in NARA’s Appraisal Policy.

The appraiser will shepherd the records schedule through the appraisal process. This process includes internal review and, for temporary records, a public comment process. The appraiser also prepares a memo for the Archivist of the United States recommending, when appropriate, approval of the schedule.

Through the appraisal process, appraisers:

• Review the schedule to make sure that it is clear and implementable
• Work with the agency to make sure that retention periods meet the agency’s needs and are not excessive
• Verify the disposition of records to make sure that records with archival value are scheduled as permanent
• Work with the agency to make sure that transfer timeframes for permanent records meet both the agency’s and NARA’s needs

The Appraisal process

Submission and Acceptance

Agencies submit records schedules through the Electronic Records Archive (ERA) system. A NARA appraiser assigned to an agency receives the schedule in the system. The appraiser reviews the schedule for acceptance.

See the section Scheduling Records for more guidance.

See the ERA Agency User Manual for detailed instructions on creating a schedule in ERA.

NARA will return schedules without action if they do not meet the standards specified in 36 CFR 1225.

NARA may need additional documentation before we can accept the schedule:

• Big bucket items must include a crosswalk
• Agencies requesting to transfer permanent records earlier than 15 years or later than 30 years must submit a form. See NARA Bulletin 2020-02: Guidance on Scheduling the Early and Late Transfer of Permanent Records for information and the forms.

If the appraiser accepts the schedule, they begin the review and approval process outlined below.

If the appraiser returns the schedule without action, the appraiser will explain what is necessary for resubmission.

Job aid: Records Schedule Quality Control Checklist 

Review

The amount of time it takes to review a schedule depends on factors such as:

• The size, scope and complexity of the schedule
• The quality of the schedule and number of revisions needed
• How many separate agency offices the appraiser needs to meet with
• How quickly the agency can arrange appraisal meetings
• How quickly the agency responds to the appraiser’s questions
• The appraiser’s workload
• Comments received during the public comment process

Appraisers review schedules to:

• Determine if proposed disposition instructions are appropriate, especially when legal rights are involved
• To ensure records proposed as permanent warrant preservation
• To ensure records proposed as temporary lack archival value

Appraisers also send schedules to internal NARA stakeholder units for review. These stakeholders include archival custody unit staff and the Federal Record Center Program. Stakeholders may ask questions about the records. They may also comment on disposition, retention periods, and transfer time frames. Stakeholders also have the opportunity to take part in appraisal meetings.

Schedule Revisions

At any time during the appraisal process an appraiser may ask the agency to revise the schedule. The appraiser will document any requested changes in communications with the agency. Agencies are usually expected to make revisions to the schedule using ERA to document changes in the ERA system.

Revisions may stem from:

• The appraiser’s review of the schedule
• Input received from other NARA units
• Comments from the public

Revisions can be made to any element of a record schedule except the agency name and Record Group. Items can also be removed or added, if needed. Most schedule revisions are to:

• Item descriptions
• Item dispositions
• Record retentions or transfer periods

Schedules are only modified by agreement between NARA and the agency.

Appraisal Meeting

Appraisers review records schedules to determine if the proposed disposition instructions are appropriate. This may involve an appraisal meeting.

The appraiser may ask to meet either in person, virtually, or on the phone. The purpose of this meetings may be to:

• Gain a better understanding of agency business processes associated with the records
• Look at examples of records
• Ask the rationale behind a proposed disposition instruction
• Discuss how the agency will carry out a proposed transfer instruction
• Answer agency questions 

Agency records management staff are responsible for arranging appraisal meetings upon request. Depending on the size and complexity of the schedule, the appraiser may need multiple meetings.

The appraisal process can move more quickly when agencies are prompt in setting up appraisal meetings and answering questions.

Agency Responsibilities for Appraisal Meetings

Appraisal Meeting Checklist

Before the appraisal meeting:

• Review and be prepared to answer Common Appraisal Questions
• Request information from your appraiser about:
  • Any specific questions they have
  • What records they want to review
  • What offices they want to meet with 
• Identify program staff to include in the meeting
  • Consult your appraiser about possible attendees
  • Collect contact information for follow-up questions
• Know where the records are kept and arrange for access
• Know what formats the records are in
• Identify any possible access issues

For virtual appraisal meetings:

Work with your NARA appraiser to decide if a virtual appraisal visit is appropriate.

Virtual appraisal meetings are appropriate when:

• When records are best viewed through system demonstrations
• When the appraiser can review records in a virtual environment
• Program staff are in different locations

Virtual appraisal meetings are not appropriate when:

• Records are fragile or unique analog formats or otherwise difficult to duplicate. This includes records such as oversized maps and glass plate negatives etc.
• Records are classified.

Identify a mutually-acceptable audio and video conferencing software that:

• Can share the screen to provide access to digital content in real time; and
• Offer multiple means of communication such as video conferencing, telephone, and chat features.

Arrange access to records in all formats and create a representative sampling.

• Ask your appraiser what records they will want to see.
• Be prepared to share records with all meeting participants during or in advance of the meeting.
  • You may need to digitize sample sets of analog records.
  • You may need to arrange for a virtual demo of an information system.
  • You may need to provide examples of electronic records from an information system.

Once the meeting dates are set:

• Send meeting location and time to all participants
  • Include building access instructions for in-person meetings 
• Work with your appraiser to develop an agenda for the meeting
• Make sure you have shared the proposed records schedule with all attendees

After the meeting:

• Arrange follow-up meetings as needed
• Answer follow-up questions from the appraiser
• Follow-up on requested schedule revisions, if needed
• The appraiser will return your schedule in ERA for you to make the revisions

Appraisal Report

When the appraiser has answers to all questions and all revisions are complete, the appraiser prepares an appraisal report. This report:

• Provides any additional information necessary to understand the records or how the agency uses them
• Explains why the proposed disposition of the records is appropriate
• Discusses any changes in retention for the records (if they were previously scheduled) and why the retention for temporary records is appropriate

Some appraisal memos outline changes the agency must make to the schedule before approval. This happens in situations where the agency has not already made requested revisions.

Other NARA offices review and comment on these reports and the schedules to which they relate.

Public Comment

Law requires that NARA publish notice in the Federal Register of schedules that propose:

• Disposal of unscheduled records 
• A reduction in the retention period of records previously scheduled as temporary 

These notices give the public an opportunity to see proposed schedules and comment on them. The public has 45 days from the date of publication to provide comments. Public input brings a non-governmental perspective to the appraisal process. Federal Register notices are available at regulations.gov.

Responding to Public Comments
NARA considers all public comments submitted by the posted deadline. If needed, the appraiser will consult with the agency to resolve comments. After considering comments, we will post a "Consolidated Reply" on regulations.gov. The Consolidated Reply summarizes and responds to the comments. It will also explain any changes we made to the proposed records schedule. You may elect to receive updates on the docket at regulations.gov.

Approval

After completion of the public comment process, the appraiser prepares the schedule for approval. The appraiser ensures the appraisal process is documented in ERA as part of the appraisal “dossier.” NARA preserves appraisal dossiers as a permanent record. NARA managers in the Office of the Chief Records Officer review the dossier before sending it to the Archivist of the United States for approval. After the Archivist approves the schedule it is available to the agency in ERA. NARA also posts a copy of the approved records schedule to the online Records Control Schedule (RCS) repository. 

Withdrawal of an Approved Disposition Authority

Authority: 36 CFR 1226.16

NARA rescinds a disposition authority when destruction of the records would harm government interests or individual rights.

This is also known as rescinding an item.

NARA notifies agencies when disposition items are rescinded:

• NARA will issue a bulletin if the withdrawal affects more than one agency.
• For temporary withdrawals, NARA will notify agencies when to resume applying the normal retention periods.
• NARA will issue further instructions for longer-lasting withdrawals.

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