Updating Schedules

Agencies are responsible for maintaining accurate and up-to-date records dispositions. This means:

• Reviewing existing schedules at regular intervals to make sure they still meet agency needs 
• Updating schedules when required
• Identifying and scheduling new records
• Implementing new GRS Transmittals

Provide a way for agency staff to suggest changes to record schedules, such as using a form like the Records Disposition Change Recommendation Form.

Reviewing Existing Schedules

NARA regulations require that agencies review all records schedules that are ten years old and older every five years. The age of the record schedule is based on the schedule’s approval date. Agencies may also review their records schedules more often. (See 36 CFR 1225.22(a).) During review, see if there are schedule items that your agency needs to revise or update.

How to Use the RCS to Review Agency Schedules: Instructions
How to Use the RCS to Review Agency Schedules: Job Aid
Inactive Item Reporting Form

Identifying Schedule Revisions

Talk to record custodians to see how schedule items are working. If your agency has automated recordkeeping, make sure that records are correctly assigned to schedule items and that disposition is taking place as expected.
Schedule items need revision when:

• Descriptions are not clear. If file custodians cannot match schedule items to their records, you need to revise item descriptions.
• Disposition instructions cannot be implemented. Do the file custodians understand the cutoff instruction for the records? Is the cutoff instruction appropriate for the records? Is it being correctly implemented? If you have automated disposition, is your recordkeeping system working as expected?
• Retention periods are too long or too short. Sometimes your agency may not have a good sense of how long to keep records when they are first scheduled. Existing retentions might end up being too long or too short. Remember that it is in your agency’s best interest to only keep temporary records as long as needed. NARA recommends starting your review with items with retention periods longer than 10 years. Make sure that these record retentions are still appropriate. Pay special attention to records with retention set out by statute or regulation. If the statute or regulation changes, your agency may need to revise the record’s retention.

If you need to revise your agency’s records schedules, follow the guidance above on when new records schedules are required. Typically, you will need to submit a new schedule to NARA for most changes.

Obsolete Items

Schedule items become obsolete when the records are no longer accumulated by the agency. Once your agency has dispositioned all existing records the schedule item is no longer needed.

Reasons schedule items may become obsolete:

• The processes that led to the creation or receipt of records change.
• The program is terminated.
• The function is transferred to another agency.
• Before identifying an item as obsolete, make sure that your agency has destroyed or transferred all records covered by the item. That includes records in record storage facilities or the Federal Records Centers.

Reporting Obsolete or Inactive Items to NARA

You can report obsolete or inactive items to NARA using the Inactive Item Reporting Form. You may send reporting forms to your agency’s appraiser or to RCS_team@nara.gov.

Non-record Materials and Filing Instructions

While reviewing older schedules you may find items that cover non-record materials or filing instructions. You can keep these types of items in your internal recordkeeping manuals or systems, but they are not disposition authorities. You should report these items to NARA so that we can identify potential inactive schedules.

When New Schedules Are Required

See also 36 CFR 1225.22.

Agencies must submit a new schedule when:

• There is an interagency reorganization. Schedules approved for one department or independent agency do not apply to the records of other departments or agencies. Agencies that take over a function for another agency must submit a new records schedule to NARA within one year. 
• Deviating from retention periods in the GRS. Many GRS items allow for longer retention. Agencies can set a longer retention for records covered by those GRS items without NARA approval. Otherwise, agencies must submit schedules requesting a GRS deviation. See Requesting GRS Deviations for more information.
• Changing retention periods for previously scheduled records.
• Change the approved disposition of records from permanent to temporary or vice versa.
• Modifying the description of records. Revisions related to the informational content or the function of the records need a new schedule. This is especially important when records move from an analog to a digital format.
• Changing the aggregation of series covered by a schedule item. Your agency must submit a new schedule to aggregate already scheduled series or to break up an aggregate item. You do not need to submit a schedule to aggregate records covered by GRS items, provided the GRS applies to all records covered by the item. See the Guide to Aggregate Item Schedules for more information on updating such items.
• Making records scheduled as temporary media neutral. Records schedules approved before December 2007 that do not say they are media neutral are media specific. Agencies wanting to apply these authorities to records in other formats must reschedule the records.
• The records schedule specifically excludes electronic records and the records are now digital. Some schedules will say that they do not apply to electronic records. Your agency cannot use these schedules for digital versions of the records. 
• Digital versions of records maintained on an agency website. Your agency cannot apply schedules for agency records to versions on agency websites. Agencies must schedule the content of websites as its own record type.
• Digitized records do not meet NARA digitization standards. See Digitization of Federal Records for more information.
• Source records that are not covered by the GRS. GRS 4.5 provides disposition authority for source records, but there are exclusions. See GRS 4.5 and its related FAQ for more information.

Other changes in an agency that may lead to schedule revisions include:

• Changes in legislation or program regulations
• Changes in program priorities, policies, procedures, or information flow
• Discontinued programs and responsibilities
• New programs and responsibilities
• Automation of work processes, such as moving from paper-based to electronic systems
• Internal reorganizations affecting the nature, content, and importance of existing records

New schedules are not required when:

• Temporarily extending the retention of temporary records. See 36 CFR 1226.18 or the section Temporarily Extending Retention of Temporary Records for further instructions.
• Changing the transfer period for permanent records. Agencies may request changes to transfer period for a single accession. Contact your agency’s appraiser or email rm.communications@nara.gov. If your agency needs to change the transfer period for all records covered by an item, submit a new record schedule to NARA. (36 CFR 1225.26(d))

Identifying New Records

Submit record schedules as soon as possible after identifying unscheduled records. 
Ways to identify new records include:

• Through the inventorying process. See Knowing Your Records for more information on inventorying your records.
• Agency staff. Consider giving agency staff a way to report when they have new records series or systems. For example, use the Records Disposition Change Recommendation Form.
• Information technology or data management divisions. These programs need to know what systems and data the agency maintains. Consider setting up a process that allows these programs to inform the records management program when they have new systems or data. They can also provide more information to help with the scheduling process. 

Implementing New GRS Transmittals

Agencies must also review their schedules when NARA issues a new or revised General Records Schedule (GRS). Agencies have six months after NARA issues a new or revised GRS to implement the GRS. Agencies have 120 days to notify NARA if they want to use existing agency authorities instead of an applicable new or revised GRS. See the Implementing GRS Transmittals for more information. See also 35 CFR 1227.

Agency records that can be covered by a new or revised GRS are automatically superseded by the GRS unless the agency submits a notification within the 120-day time period after GRS issuance. See Submitting GRS Notifications for more information.

How to Update Schedules

A new schedule is required to update an existing schedule. Follow the instructions for Creating the Records Schedule and refer to Scheduling Records as needed.

When rescheduling previously approved disposition items:

• List any superseded schedule items. 
• State whether the superseded item is superseded fully or in part.
• Be prepared to explain to your appraiser why the records are being rescheduled. If the record retention is changing, your appraiser will want to know why.

For information on updating aggregate item schedules, see the Guide to Aggregate Item Schedules.

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