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Report to the Ranking Member, Committee on Finance, U.S. Senate: 

United States Government Accountability Office:
GAO: 

October 2010: 

National Archives And Records Administration: 

Oversight and Management Improvements Initiated, but More Action 
Needed: 

GAO-11-15: 

GAO Highlights: 

Highlights of GAO-11-15, a report to the Ranking Member, Committee on 
Finance, U.S. Senate. 

Why GAO Did This Study: 

The mission of the National Archives and Records Administration (NARA) 
is to safeguard and preserve government records, ensuring continuing 
access to the essential documentation of the rights of American 
citizens and the actions of their government. However, in today’s 
environment of fast-evolving information technology, federal agencies 
are creating vast and growing volumes of electronic records while 
continuing to create physical records in large numbers.
Accordingly, GAO was asked to assess NARA’s effectiveness in 
overseeing the governmentwide management of records, including 
commenting on its capacity to identify risk of unlawful destruction of 
federal records; describe its ability to preserve permanent records; 
and assess its policies, procedures, and plans supporting key 
management and oversight capabilities (collaboration, governance, and 
human capital). To do so, GAO analyzed NARA documentation in these 
areas, interviewed agency officials, and reviewed prior work. 

What GAO Found: 

The effectiveness of NARA’s oversight has been improved by recent 
increases in its oversight activities: NARA has conducted its first 
governmentwide records management self-assessment survey, resumed 
agency inspections after a long gap, and expanded its reporting 
(including giving more complete information about specific agencies). 
These efforts have provided a fuller picture of governmentwide records 
management: in particular, NARA found that almost 80 percent of 
agencies were at moderate to high risk of unlawful destruction of 
records. Reporting of such results may also help influence agencies to 
give more priority to records management, which has historically been 
given low priority. However, these initiatives have limitations. For 
example, NARA’s efforts to validate self-reported survey data are 
limited, as are its plans for inspections of agency records 
management; addressing these limitations could enhance the usefulness 
of these efforts as they continue to be developed. NARA also oversees 
agency records management through its review and approval of the 
schedules under which agencies may dispose of records. Following an 
extended effort to get agencies to schedule electronic records and 
systems, NARA increased the number of schedules approved per year. 
However, it has also increased the backlog of schedules awaiting its 
approval, increasing the risk that NARA’s success in promoting 
scheduling could bring in more schedules than it can handle in a 
timely manner. 

NARA faces challenges in preserving permanent records largely because 
of their volume, the finite resources available, and the technological 
challenges posed by electronic records. NARA has a large and 
persistent backlog of records on paper and other media needing 
preservation actions. Although it treated nearly 116,000 cubic feet of 
at-risk archival records in fiscal year 2009, the percentage of 
backlog remained constant at about 65 percent, and holdings requiring 
preservation grew from about 2.4 million cubic feet in 2008 to about 
2.6 million cubic feet in 2009. For electronic records, NARA has an 
electronic records archive system that is still under development and 
does not yet include planned preservation functions. Until the system 
and its preservation capabilities are fully implemented, there is 
reduced assurance that NARA can ensure the preservation of all 
electronic records. 

NARA’s policies and procedures for collaboration, selected aspects of 
governance, and human capital are generally aligned with its strategic 
planning. For example, it is participating in numerous collaborative 
activities that support the goals and strategies in its strategic 
plan. However, more action is needed. For example, with regard to 
governance, although its organizational responsibilities are generally 
aligned with its strategic plan, NARA has not established an 
enterprise risk management capability, reducing its ability to 
anticipate future challenges and avoid potential crises. Finally, NARA 
has developed and begun to implement a strategic human capital plan, 
but this implementation has been delayed, which hinders the agency’s 
ability to ensure that it has the workforce and skills it needs. 

What GAO Recommends: 

GAO is making recommendations to help NARA build on its recent 
oversight activities and to fill gaps in its risk management and human 
capital management. In comments on a draft of the report, NARA 
concurred. 

View [hyperlink, http://www.gao.gov/products/GAO-11-15] or key 
components. For more information, contact Valerie C. Melvin at (202) 
512-6304 or melvinv@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

NARA Is Improving its Oversight Activity, but More Remains to Be Done: 

NARA's Ability to Preserve Federal Records Is Strained by Volume of 
Records, Finite Resources, and Technology: 

In Key Management Areas, NARA Has Policies and Procedures that Are 
Consistent with Its Strategic Planning, although Gaps Remain: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the National Archives and Records 
Administration: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: NARA Organizations, Missions, and Staffing: 

Table 2: Organizations, Functions, and Staffing of Office of Records 
Services, Washington, D.C. 

Table 3: NARA Studies Performed or Planned Since 2008 GAO Report: 

Table 4: Inspections Performed or Planned: 

Table 5: Review Process for Records Schedules: 

Table 6: NARA's Strategic Goals: 

Table 7: Strategies Lacking Clear Lines of Responsibility: 

Table 8: NARA's Strategic Goals and Collaboration Strategies: 

Table 9: Collaborative Efforts Related to NARA's Strategic Goals: 

Figures: 

Figure 1: NARA Organizational Chart: 

Figure 2: Reported Allocation of Total Fiscal Year 2009 Direct 
Appropriations of $486,031,000: 

Figure 3: GAO Risk Management Framework: 

Figure 4: Overview of Strategic Approach to Human Capital Management: 

Figure 5: Status of Human Capital Strategic Plan Milestones: 

Abbreviations: 

ERA: Electronic Records Archives: 

FTE: full-time equivalent: 

GPRA: Government Performance and Results Act: 

GSA: General Services Administration: 

NARA: National Archives and Records Administration: 

NCAST: NARA's Center for Advanced Systems and Technologies: 

NGA: National Geospatial-Intelligence Agency: 

OMB: Office of Management and Budget: 

OPM: Office of Personnel Management: 

OSD: Office of the Secretary of Defense: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

October 5, 2010: 

Senator Charles E. Grassley: 
Ranking Member: 
Committee on Finance: 
United States Senate: 

Dear Senator Grassley, 

The mission of the National Archives and Records Administration (NARA) 
is to safeguard and preserve government records, ensuring continuing 
access to the essential documentation of the rights of American 
citizens and the actions of their government. However, in today's 
environment of fast-evolving information technology, this important 
mission is increasingly challenging. At the same time that paper and 
other physical records continue to be created in large numbers, 
federal agencies are creating vast and growing volumes of electronic 
records. 

In light of this challenging environment, you asked us to undertake a 
review of the agency's ability to effectively carry out its mission of 
overseeing the management of federal records while preserving those of 
historic and intrinsic value. 

As agreed, our objectives were to (1) assess NARA's effectiveness in 
overseeing the governmentwide management of records, including 
commenting on its capacity to identify risk of unlawful destruction of 
federal records; (2) describe its ability to preserve permanent 
records; and (3) assess its policies, procedures, and plans supporting 
key management and oversight capabilities: governance, human capital, 
and collaboration. 

To assess NARA's effectiveness in overseeing governmentwide records 
management, we examined its use of the oversight activities--surveys, 
studies, inspections, and reporting--defined in the Federal Records 
Act and its process for approving records schedules. We examined 
documents, interviewed agency officials, and obtained input from a 
panel of experts and from other federal records managers. To comment 
on NARA's capacity to identify risk of unlawful destruction of federal 
records, we reviewed applicable laws, reviewed the results of a NARA 
survey, and met with NARA records management staff to identify risk 
factors. 

To describe NARA's ability to preserve permanent records, we met with 
NARA preservation staff; reviewed NARA's survey of its physical 
records and its backlog of records needing preservation actions and 
assessed their reliability; and analyzed NARA's ability to process its 
backlog. We also reviewed external research on electronic records, 
interviewed staff involved in developing NARA's Electronic Records 
Archives (ERA) system, and drew on our previous reports about the 
status of ERA. 

To assess NARA's policies, procedures, and plans supporting key 
management and oversight capabilities, we analyzed NARA management, 
strategic planning, and policy documents against requirements of the 
Government Performance and Results Act (GPRA)[Footnote 1] and our risk 
management framework in order to determine whether NARA lines of 
responsibility were aligned with its strategic plans and whether it 
was conducting an appropriate risk management program. To assess human 
capital management, we compared NARA's human capital management 
capabilities and its human capital strategic plan against our 
Strategic Human Capital Framework.[Footnote 2] We interviewed NARA 
officials and reviewed progress in implementing its human capital plan 
against the plan's milestones. To evaluate NARA's collaboration 
capabilities, we interviewed policy and planning staff, analyzed 
agency policies and procedures related to collaboration, obtained a 
list of NARA collaborative projects, and examined whether 
collaborative activities specified in the strategic plan were being 
carried out. 

We reached out to the federal records management community to obtain 
information on several issues. We worked with the National Academy of 
Sciences to convene a panel of experts. We also obtained views of 
selected federal government records managers at the Department of 
Defense and surveyed members of the Federal Information and Records 
Managers Council, an organization of federal records managers. 
Appendix I provides further details on our objectives, scope, and 
methodology. 

We conducted this performance audit from October 2009 to October 2010 
in the Washington, D.C., metropolitan area in accordance with 
generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings 
and conclusions based on our audit objectives. We believe that the 
evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Background: 

NARA's mission is to safeguard and preserve the records of the U.S. 
government, ensuring that the people can discover, use, and learn from 
this documentary heritage. In this way, NARA is to ensure continuing 
access to the essential documentation of the rights of American 
citizens and the actions of their government. 

In carrying out this mission, NARA (among other things) is to provide 
guidance and assistance to federal officials on the management of 
records; determine the retention and disposition of records; store 
agency records in records centers from which agencies can retrieve 
them; receive, preserve, and make available permanently valuable 
federal and presidential records; and centrally file and publish 
federal laws and administrative regulations, the President's official 
orders, and the structure, functions, and activities of federal 
agencies through the daily Federal Register. 

NARA Organization and Functions: 

NARA is organized into six main offices, as well as a number of 
offices carrying out particular functions. As shown in the 
organization chart in figure 1, of NARA's six major offices, two are 
support offices (the Office of Administration and the Office of 
Information Services), and four carry out the organization's primary 
missions (the Offices of Records Services, Washington, D.C.; Regional 
Records Services; the Federal Register; and Presidential Libraries). 
In addition, four independent offices with specialized missions report 
directly to the Archivist of the United States, and various staff 
offices (such as General Counsel) provide support. 

Figure 1: NARA Organizational Chart: 

[Refer to PDF for image: Organizational Chart] 

Top level: 
Archivist of the United States: 
* Deputy Archivist of the United States; 
* Chief of Staff. 

Staff offices: 
* Congressional Affairs Staff; 
* General Counsel; 
* Policy and Planning Staff; 
* Public Affairs and Communications Staff; 
* EEO and Diversity Programs. 

Independent offices that report directly to the Archivist: 
* Information Security Oversight Office; 
* National Historical Publications and Records Commission; 
* Office of Government Information Services; 
* Office of the Inspector General. 

Major offices: 
* Office of Records Services, Washington, D.C. 
* Office of Regional Records Services; 
* Office of Presidential Libraries; 
* Office of the Federal Register; 
* Office of Information Services; 
* Office of Administration. 

Source: NARA. 

[End of figure] 

Table 1 shows these organizations, major functions, and the levels of 
staff in each (expressed as full-time equivalent--FTE). 

Table 1: NARA Organizations, Missions, and Staffing: 

Organization: Office of the Archivist and staff offices; 
Mission and functions: Plan, develop, and administer NARA programs and 
functions; 
FTEs[A]: 81. 

Major offices: Office of Records Services, Washington, D.C.; 
Mission and functions: Takes custodial responsibility for the 
historically valuable records of the three branches of the federal 
government in the Washington, D.C., area. Appraises,[B] accessions,c 
preserves, describes, and provides access to these records. Provides 
records management services to Washington, D.C., area; 
FTEs[A]: 810. 

Major offices: Office of Regional Records Services; 
Mission and functions: Operating on a reimbursable fee-for-service 
basis, stores federal agency records in 17 records centers nationwide. 
Also provides records management services to regions and operates 
regional archives; 
FTEs[A]: 1,481. 

Major offices: Office of Presidential Libraries; 
Mission and functions: Administers a nationwide network of 13 
presidential libraries; 
FTEs[A]: 435. 

Major offices: Office of the Federal Register; 
Mission and functions: Promulgates and publishes federal documents 
under the Federal Register Act and other acts; 
FTEs[A]: 58. 

Major offices: Office of Administration; 
Mission and functions: Performs administrative services including 
management of acquisitions, finance, budget, facilities, property, 
human resources, organization and staff development, security, and 
duties of the Chief Financial Officer; 
FTEs[A]: 182. 

Major offices: Office of Information Services; 
Mission and functions: Carries out NARA's information technology 
program and duties of the Chief Information Officer (CIO); 
FTEs[A]: 117. 

Independently reporting offices: Information Security Oversight Office; 
Mission and functions: Administers the program for classifying, 
safeguarding, and declassifying national security information. Also 
responsible for policy and oversight of the governmentwide security 
classification system and the National Industrial Security Program; 
FTEs[A]: 29. 

Independently reporting offices: National Historical Publications and 
Records Commission; 
Mission and functions: A grant-making affiliate of NARA, established 
by Congress to promote the preservation and use of America's 
documentary heritage. Funds institutions engaged in archives-related 
activities; 
FTEs[A]: 9. 

Independently reporting offices: Office of Government Information 
Services; 
Mission and functions: Reviews Freedom of Information Act activities 
governmentwide and helps to resolve disputes between requesters and 
agencies; 
FTEs[A]: 6. 

Independently reporting offices: Office of the Inspector General; 
Mission and functions: Carries out audits, investigations, 
inspections, management assistance, and reports relating to the 
administration of NARA's programs and operations; 
FTEs[A]: 20. 

Total: 
FTEs[A]: 3,228. 

Source: GAO analysis of NARA information. 

[A] NARA staffing projections as of July 2010. 

[B] Appraisal is the process by which NARA determines the value and 
thus the final disposition of federal records. 

[C] Accession is the act and procedures involved in a transfer of 
records into the legal custody of the National Archives. 

[End of table] 

NARA's operations are dispersed throughout more than 40 facilities in 
the United States. These facilities include the National Archives 
Building in Washington, D.C. (housing the nation's founding 
documents); the nearby Archives II facility in College Park, Maryland; 
and its nationwide network of regional archives, records centers, and 
presidential libraries and museums. 

Organizations Primarily Responsible for Federal Records Management and 
Preservation: 

Two offices share primary responsibility for performing NARA's mission 
to safeguard and preserve federal records: the Office of Records 
Services, Washington, D.C., and the Office of Regional Records 
Services. These offices also account for more than two-thirds of 
NARA's approximately 3,200 FTE employees.[Footnote 3] 

The Office of Records Services, Washington, D.C., has custodial 
responsibility for the historically valuable records of the three 
branches of the federal government in the Washington, D.C., area. 
Through its programs, the office appraises, accessions, preserves, 
describes, and provides access to these records. Besides the head 
office, it has six main subdivisions, as shown in table 2. 

Table 2: Organizations, Functions, and Staffing of Office of Records 
Services, Washington, D.C. 

Organization: Head office (Assistant Archivist for Records Services, 
Washington, D.C.); 
Function: Develops, coordinates, and monitors overall plans, programs, 
and resource allocations for the office; 
FTEs[A]: 16. 

Organization: Access Programs; 
Function: Responsible for archival services and customer services 
relating to records accessioned to the Archives; 
FTEs[A]: 388. 

Organization: Center for the National Archives Experience; 
Function: Responsible for museum, visitor, and educational services 
and special events; 
FTEs[A]: 35. 

Organization: National Declassification Center; 
Function: Responsible for direct guidance, technical support, and 
assistance to federal agencies relating to declassification matters; 
conducts reviews and plans and coordinates agency reviews of security-
classified materials for declassification; 
FTEs[A]: 66. 

Organization: Center for Legislative Archives; 
Function: Responsible for managing, preserving, and providing access 
to legislative records; 
FTEs[A]: 19. 

Organization: Modern Records Programs; 
Function: Responsible for NARA's nationwide records management program; 
FTEs[A]: 195. 

Organization: Preservation Programs; 
Function: Responsible for long-range preservation of federal, 
presidential, and donated materials; 
FTEs[A]: 91. 

Total: 
FTEs[A]: 810. 

Source: GAO analysis of NARA information. 

[A] NARA staffing projections as of July 2010. 

[End of table] 

The Office of Regional Records Services is organized into nine regions 
(each headed by a Regional Administrator) plus the National Personnel 
Records Center in St. Louis, Missouri. Each region operates records 
centers, regional archives, and records management programs for the 
region. In all, the Office of Regional Records Services manages 17 
records centers nationwide, which operate on a reimbursable fee-for- 
service basis. They provide federal agencies with storage of agency 
records not needed in day-to-day operations, among other services, 
including records management assistance. The regional archives provide 
the public with free access to the significant historical records of 
federal agencies for purposes of education, genealogy, history, and 
research, as well as to facilitate publications in all media. Of the 
staff of more than 1,400, about half (745) are assigned to the Federal 
Personnel Records Center, with the rest allocated to the regions. 

In addition, the Office of Information Services plays an important 
role in records management and preservation through two of its 
components: 

* The Electronic Records Archives Program Office manages the program 
to develop ERA, a system that is intended to preserve and provide 
access to huge volumes of all types and formats of electronic records, 
independent of their original hardware or software. 

* The Center for Advanced Systems and Technologies works to discover 
and promote archival technologies, including preservation 
technologies, to NARA's offices. 

To coordinate records management activities that are performed in both 
headquarters and the regions, NARA set up the National Records 
Management Program, headed by the Director of Modern Records Programs 
within the Office of Records Services, Washington, D.C. Among the 
goals of setting up the National Records Management Program was to be 
more responsive to NARA and agency records management needs and goals, 
improve internal communications, and help clarify staff roles and 
responsibilities. The program includes about 100 records management 
staff working in both the Washington, D.C., office and the regions 
(each region operates one or more records center facilities, each of 
which has two to four staff that perform records management work). 

NARA Funding and Allocation of Budget Authority: 

NARA's fiscal year 2009 appropriation was about $459 million, while 
its fiscal year 2010 appropriation is about $470 million. NARA's 
budget request for fiscal year 2011 is about $460 million. In addition 
to annual appropriations acts, NARA's operations are funded through 
revenues from the National Archives Trust Fund,[Footnote 4] Gift Fund, 
[Footnote 5] and Revolving Fund (which funds the operations of the 
regional records centers).[Footnote 6] NARA's operations at the 
presidential libraries are also partially supported by a Presidential 
Library Trust Fund.[Footnote 7] 

Figure 2 provides the reported breakdown of the allocation of budget 
authority provided to NARA by annual appropriations acts for fiscal 
year 2009 ($486 million, which includes $26 million carried over in 
multi-year and no-year funds available for obligation). 

Figure 2: Reported Allocation of Total Fiscal Year 2009 Direct 
Appropriations of $486,031,000: 

[Refer to PDF for image: pie-chart] 

Records Services, $134,453,000 (27.7%); 
Presidential Libraries, $92,373,000 (19%); 
Repairs and Restoration, $75,010,000 (15.4%); 
Electronic Records Archives, $67,642,000 (13.9%); 
Regional Records Services, $56,135,000 (11.6%); 
Archives II Debt Redemption and Interest, $28,971,000 (6%); 
NHPRC, $12,382,000 (2.6%); 
Federal Register, $11,199,000 (2.3%); 
Information Security Oversight Office, $4,814,000 (1.0%); 
Office of Inspector General, $3,052,000 (0.6%); 

Source: GAO analysis of NARA data. 

Note: Entry for NHPRC covers grants and operating expenses for the 
National Historical Publications and Records Commission 

[End of figure] 

NARA's Responsibilities for Records Management and Preservation: 

The Federal Records Act gives NARA responsibilities regarding both 
federal records management and preservation of permanent records. 
[Footnote 8] Thus, NARA supports agency management of records used in 
everyday operations (both temporary and permanent) and ultimately 
takes control of permanent agency records judged to be of historic 
value. Of the total number of federal records, NARA estimates that 
less than 3 percent are designated permanent. 

Responsibility for Records Management Is Shared across the Government: 

By statute, some of the responsibilities for oversight of federal 
records management are divided across several agencies. Under the 
Federal Records Act, NARA shares a number of records management 
responsibilities and authorities with the General Services 
Administration (GSA).[Footnote 9] Under the Paperwork Reduction Act 
[Footnote 10] and the E-Government Act,[Footnote 11] the Office of 
Management and Budget (OMB) also has records management oversight 
responsibilities. 

Further, the heads of federal agencies are responsible for their 
agencies' records. The Federal Records Act establishes requirements 
for records management programs in federal agencies. Each federal 
agency is required to make and preserve records that (1) document the 
organization, functions, policies, decisions, procedures, and 
essential transactions of the agency and (2) provide the information 
necessary to protect the legal and financial rights of the government 
and of persons directly affected by the agency's activities. (NARA is 
assigned responsibilities for assisting federal agencies in this 
area.) Effective management of these records is critical for ensuring 
that sufficient documentation is created; that agencies can 
efficiently locate and retrieve records needed in the daily 
performance of their missions; and that records of historical 
significance are identified, preserved, and made available to the 
public. 

Records must be managed at all stages of their life cycle, which 
includes records creation or receipt, maintenance and use, and 
disposition. Agencies create records to meet the business needs and 
legal responsibilities of federal programs and (to the extent known) 
the needs of internal and external stakeholders who may make secondary 
use of the records. To maintain and use the records created, agencies 
are to establish internal recordkeeping requirements for maintaining 
records, consistently apply these requirements, and establish systems 
that allow them to find records that they need. Disposition involves 
transferring records of permanent, historical value to NARA for 
archiving (preservation) and destroying all other records that are no 
longer needed for agency operations. 

NARA is responsible for issuing records management guidance; working 
with agencies to implement effective controls over the creation, 
maintenance, and use of records in the conduct of agency business; 
approving the disposition (destruction or preservation) of records; 
and providing storage facilities for agency records. The Federal 
Records Act also gives NARA the responsibility for conducting 
inspections or surveys of agencies' records and records management 
programs and practices; conducting records management studies; and 
reporting the results of these activities to the Congress and OMB. 

NARA Must Approve Disposition of Federal Records: 

Under the Federal Records Act, disposition of any records (destruction 
or transfer to the Archives for preservation) requires the approval of 
the Archivist of the United States. Scheduling is the means by which 
NARA and agencies identify federal records and determine time frames 
for disposition. Creating records schedules involves identifying and 
inventorying records, appraising their value, determining whether they 
are temporary or permanent, and determining how long records should be 
kept before they are destroyed or turned over to NARA for archiving. 
For example, one general records schedule permits civilian agencies to 
destroy case files for merit promotions (2 years after the personnel 
action is completed or after an audit by the Office of Personnel 
Management, whichever is sooner). No record may be destroyed or 
permanently transferred to NARA unless it has been scheduled, so the 
schedule is of critical importance. Without schedules, agencies would 
have no clear criteria for when to dispose of records and, to avoid 
disposing of them unlawfully, would have to maintain them indefinitely. 

NARA works with agencies to help schedule records, and it must approve 
all agency records schedules. It also develops and maintains general 
records schedules covering records common to several or all agencies. 
According to NARA, records covered by general records schedules make 
up about a third of all federal records. For the other two thirds, 
NARA and the agencies must agree upon agency-specific records 
schedules. 

Destruction of records before their scheduled disposition date or 
without NARA approval is unauthorized and unlawful. Specifically, 
unlawful destruction occurs when: 

* permanent records or records that have not been scheduled are 
destroyed, 

* temporary records are destroyed before the end of their retention 
period, or: 

* records required to be held for other reasons, such as litigation or 
Freedom of Information Act requests, are destroyed.[Footnote 12] 

Agency heads are responsible for preventing unauthorized destruction 
of records and must make sure employees are informed about the 
requirement, implement policies and procedures to ensure that records 
are protected, and report any unauthorized removal or destruction to 
NARA.[Footnote 13] If NARA learns of a potential or actual instance of 
unlawful destruction, the Archivist is required to notify the agency 
head and assist in initiating action through the Attorney General for 
the recovery of records and other redress. If the head of the agency 
does not initiate an action within a reasonable period of time, the 
Archivist is to request the Attorney General to act and notify the 
Congress. 

NARA Is Responsible for Preservation of Permanent Records: 

As the nation's archivist, NARA is the legal custodian of the records 
of federal agencies that are determined to have sufficient historical 
or other value to warrant their continued preservation by the U.S. 
government. NARA also accepts for deposit to its archives many of the 
records of the Congress, the Architect of the Capitol, and the Supreme 
Court. In addition, NARA accepts papers and other historical materials 
of the presidents of the United States, documents from private sources 
that are appropriate for preservation (including electronic records, 
motion picture films, still pictures, and sound recordings), and 
records from agencies whose existence has been terminated. 

NARA archives vast quantities of federal records in various formats. 
According to the agency, its 28 archives and presidential libraries 
across the United States hold almost 4 million cubic feet of permanent 
federal paper, photographic, audio, video, and film records and 
600,000 artifacts. Its multimedia collections include nearly 300,000 
reels of motion picture film; more than 15 million maps, charts, 
aerial photographs, architectural drawings, patents, and ship plans; 
more than 200,000 sound and video recordings; and nearly 6 million 
photographs and graphics. In addition, as of August 2010, NARA has 
archived about 82.4 terabytes of electronic information.[Footnote 14] 

To preserve electronic records, NARA has been working since 2001 to 
develop an electronic records archive system that is intended to 
preserve and provide access to very large volumes of all types and 
formats of electronic records, independent of their original hardware 
or software. NARA plans for the system to manage the electronic 
records from their ingestion through preservation and dissemination to 
customers. The ERA system is being developed in five phases, or 
increments. NARA has certified initial operating capability of the 
first two phases of ERA. NARA plans to complete development of the 
remaining increments and achieve full operating capability by 2012. 

We Have Previously Reported on NARA's Challenges and Federal Records 
Management: 

We have previously reported on the risks NARA faces in its acquisition 
of ERA, on NARA's oversight of federal records management, and on the 
challenges of electronic records management. 

From 2002 onward, we have issued a series of reports on ERA and its 
development.[Footnote 15] Most recently, we reported, among other 
things, that NARA's plans for completing the final two increments were 
not sufficiently specific: the most recent expenditure plan did not 
detail what system capabilities would be delivered in the final two 
ERA increments or dates for completion.[Footnote 16] Further, NARA's 
management of the requirements for ERA had weaknesses: NARA had 
established an initial set of high-level requirements to guide the 
system's development, but about 43 percent of the requirements had not 
been allocated to the last two increments, and NARA officials stated 
that it was uncertain whether they would be implemented at all. 
Finally, NARA stated that it had reinterpreted some of the 
requirements in its original requirements document but had not updated 
it. The lack of a current set of requirements is a significant risk. 
If requirements are incomplete and out of date, the system could be 
completed without addressing all necessary requirements or with 
functionality that meets requirements that are no longer valid. 
Accordingly, we recommended that NARA ensure that ERA's requirements 
are managed using a disciplined process that ensures that requirements 
are traceable throughout the project's life cycle and are kept current. 

We have also made recommendations to NARA on its oversight of federal 
records management. Our recommendations were aimed at improving NARA's 
insight into the state of federal records management as a basis for 
determining where its attention is most needed. In 1999, in reporting 
on the substantial challenge of managing and preserving electronic 
records in an era of rapidly changing technology,[Footnote 17] we 
noted that NARA did not have governmentwide data on the electronic 
records management capabilities and programs of all federal agencies. 
Accordingly, we recommended that NARA conduct a governmentwide survey 
of these programs and use the information as input to its efforts to 
re-engineer its business processes. However, instead of doing a 
governmentwide baseline assessment survey as we recommended, NARA 
planned to obtain information from a limited sample of agencies, 
stating that it would evaluate the need for such a survey later. 
[Footnote 18] 

In 2002, we reported that because NARA did not perform systematic 
inspections of agency records management, it did not have 
comprehensive information on implementation issues and areas where 
guidance needed strengthening.[Footnote 19] We noted that in 2000, 
NARA had suspended agency evaluations (inspections) because it 
considered that these reached only a few agencies, were often 
perceived negatively, and resulted in a list of records management 
problems that agencies then had to resolve on their own. We 
recommended that it develop a strategy for conducting systematic 
inspections of agency records management programs to (1) periodically 
assess agency progress in improving records management programs and 
(2) evaluate the efficacy of NARA's governmentwide guidance. 

In response to our recommendations, NARA devised a strategy for a 
comprehensive approach to improving agency records management that 
included inspections and identification of risks and priorities. 
Subsequently, it also developed an implementation plan that included 
undertaking agency inspections based on a risk-based model, government 
studies, or media reports.[Footnote 20] 

In 2008, we reported that under its oversight strategy, NARA had 
performed or sponsored six records management studies in the previous 
5 years, but it had not conducted any inspections since 2000 because 
it used inspections only to address cases of the highest risk, and no 
recent cases met its criteria.[Footnote 21] In addition, NARA's 
reporting to the Congress and OMB did not consistently provide 
evaluations of responses by federal agencies to its recommendations, 
as required, or details on records management problems or recommended 
practices that were discovered as a result of inspections, studies, or 
targeted assistance projects. Accordingly, we recommended that NARA 
develop and implement an oversight approach that provides adequate 
assurance that agencies are following NARA guidance, including both 
regular assessments of agency records and records management programs 
and reporting on these assessments. NARA agreed with our 
recommendations and devised a strategy that included annual self- 
assessment surveys, inspections, and reporting, which it has now begun 
to implement. 

Most recently, we testified on the challenges of managing electronic 
records and commented on the low priority that records management has 
historically received within the federal government.[Footnote 22] Our 
past reports identified persistent weaknesses in federal records 
management, including a lack of policies and training. We also noted 
some of the challenges of managing electronic records: For example, 
electronic information is being created in volumes that pose a 
significant technical challenge to our ability to organize and make it 
accessible. Electronic records range in complexity from simple text 
files to highly complex formats with embedded computational formulas 
and dynamic content, and new formats continue to be created. Further, 
in a decentralized environment, it is difficult to ensure that records 
are properly identified and managed by end users on individual 
desktops (the "user challenge"). We concluded that technology alone 
cannot solve the problem without commitment from agencies, noting 
(among other things) that automation will not solve the problem of 
lack of priority given to records management, which is of long 
standing. 

NARA Is Improving its Oversight Activity, but More Remains to Be Done: 

The effectiveness of NARA's oversight activity has been improved by 
recent initiatives. However, these initiatives have limitations, and 
NARA's oversight alone cannot solve the persistent problems facing 
federal records management.[Footnote 23] 

* NARA has begun to increase its efforts to assess governmentwide 
records management and its reporting of results. Although the Federal 
Records Act gives NARA responsibility for oversight activities 
(including inspections, surveys, and reporting), until recently, its 
performance of these activities was limited. It has now completed its 
first governmentwide records management self-assessment survey, 
resumed agency inspections after a long gap, and increased its 
reporting. These new efforts have provided NARA with a fuller picture 
of governmentwide records management, including an assessment by 
agency of the risk of unauthorized destruction of federal records; as 
a result, it is in a better position to determine where records 
management improvements are most needed, develop and update guidance, 
and hold agencies accountable by publishing assessments of their 
records management programs. NARA plans to use these oversight 
activities to develop baselines against which to assess future 
progress; however, it has not yet developed plans for adequately 
validating self-reported data or targeting inspections of agency 
records and records management programs to achieve governmentwide 
results. As NARA continues to build its oversight program, such 
activities will be important to provide assurance that reported 
changes from baseline scores reasonably reflect actual performance. 

* NARA also provides oversight through its appraisal and scheduling 
work with agencies, in which it appraises agency records for their 
permanent value (among other things) and reviews and approves agency 
disposition schedules, in accordance with the Federal Records Act. 
Following an extended effort to get agencies to submit schedules for 
unscheduled systems containing electronic records, NARA has increased 
the number of schedules it has approved per year, but nevertheless has 
an increased backlog of schedules awaiting approval. NARA faces the 
risk that its success in getting agencies to schedule their systems 
may result in more schedules being submitted than it can handle in a 
timely manner. Unless NARA assesses this risk and develops appropriate 
mitigation plans, the backlog may increasingly hinder agencies' 
records management. 

Although NARA activities alone cannot solve the persistent problems 
facing federal records management (agency heads are responsible for 
their agencies' records and records management), building and 
improving on NARA's oversight activities could help both NARA and 
agencies more effectively focus resources on areas needing improvement. 

NARA Uses Surveys, Studies, and Inspections to Assess Governmentwide 
Records Management, but Limitations Remain to Be Addressed: 

Oversight addresses whether organizations are carrying out their 
responsibilities and serves to detect other shortcomings. Our reports 
emphasize the importance of effective oversight of government 
operations by individual agency management, by agencies having 
governmentwide oversight responsibilities, and by the Congress. 
Various functions and activities may be part of oversight, including 
monitoring, evaluating, and reporting on the performance of 
organizations and their management and holding them accountable for 
results. 

The Federal Records Act gave NARA responsibility for oversight of 
agency records management programs by, among other functions, making 
it responsible for conducting inspections or surveys of agencies' 
records and records management programs and practices; conducting 
records management studies; and reporting the results of these 
activities to the Congress and OMB.[Footnote 24] Consequently, as our 
previous work pointed out, it is important for NARA to have a 
governmentwide picture of the state of federal records management 
programs to help it to hold agencies accountable, as well as to 
determine areas where its guidance needs strengthening.[Footnote 25] 

NARA has recently undertaken efforts to gather governmentwide 
information to help it assess the status of federal records management 
and risks of unauthorized disposition (including destruction) of 
records. In September 2009, NARA sent the first of a promised series 
of annual mandatory records management self-assessment surveys to 242 
federal records officers from cabinet-level agencies, agency 
components, and independent agencies; the survey's goal was to 
determine how effectively agencies were meeting statutory and 
regulatory requirements for records management. Agencies were asked 34 
questions designed to obtain basic information about agencies' records 
management programs in five areas: program management, records 
disposition, vital records, electronic records, and e-mail records. 
NARA used the data collected to categorize agencies according to the 
level of risk to records associated with the state of agencies' 
records management programs. According to NARA, ineffective records 
management programs are the most significant indicators of risk of 
unauthorized disposition of records.[Footnote 26] 

NARA's report on the self-assessment survey, released in April 2010, 
[Footnote 27] described strengths and weaknesses in agencies' records 
management programs. It concluded that almost 80 percent of agencies 
were at moderate or high risk of improper destruction of 
records;[Footnote 28] that is, the risk that permanent records will be 
lost or destroyed before they can be transferred to NARA for archiving 
or that other records will be lost while they are still needed for 
government operations or legal obligations. In particular, of the 220 
(91 percent) federal agencies and components that responded, 36 
percent were at high risk in their records management programs and 43 
percent were at moderate risk. Overall, only 21 percent of federal 
agencies and components responding were at low risk. For electronic 
records, 39 percent were at high risk, and for e-mail, 48 percent were 
at high risk. The Archivist referred to these results as "alarming" 
and "worrisome";[Footnote 29] in a subsequent oversight hearing, the 
director of NARA's Modern Records Program testified that the findings 
were "troubling" and "unacceptable." 

NARA has also obtained governmentwide information on one facet of 
records management--electronic records scheduling--through its efforts 
to ensure that electronic systems holding records are scheduled. NARA 
has periodically requested agencies to provide summary reports 
documenting their progress.[Footnote 30] By September 30, 2009, NARA 
had received electronic records scheduling reports from 160 of 240 
federal agencies or components for which it had been tracking 
electronic records scheduling, for a 67 percent response rate. In June 
2010, it summarized the results of these reports.[Footnote 31] NARA 
determined that 25 percent were in the moderate to high risk category 
for failing to schedule 90 percent or more of their electronic 
records. Forty-two percent were rated low risk, and 33 percent did not 
respond to NARA's request for information. 

These information-gathering efforts are important means for helping to 
assess federal records management and risks to records. The 2009 self- 
assessment in particular provided NARA useful oversight information, 
including a broad picture of governmentwide records management that 
was not previously available. The self-assessment survey adds to 
NARA's ability to assess the risk of unauthorized destruction of 
records by increasing its broad knowledge of the status of agency 
records management programs; previously, although NARA's regular work 
with agencies on scheduling and disposition of records provided it 
insight into agencies' activities at the end of the records life 
cycle, NARA officials agreed that its insight into records management 
at earlier stages--that is, creation, maintenance, and use--had been 
more limited. 

In addition, NARA's work conducting the self-assessment survey raised 
issues for further study, such as the role of the departmental records 
officer and appropriate level of records management staffing. It also 
provided NARA with important operational experience to apply to 
improving further surveys. According to the survey report, the results 
of the first few self-assessments will provide a baseline for records 
management in the federal government and, along with findings from 
agency inspections and records management studies, will allow it to 
assess more thoroughly records management within individual agencies 
and throughout the federal government. NARA has committed to 
conducting the self-assessment survey annually, and it conducted a 
second survey in May and June 2010 (at the time of our review, NARA 
had not yet published the results of this second survey). 

In addition, NARA has increased its reporting on the results of its 
oversight activities. In the past, NARA had been reluctant to report 
negative news about individual agencies' records management, which we 
attributed to an organizational preference for using persuasion and 
cooperation when working with agencies.[Footnote 32] We noted that 
this reduced its ability to hold agencies accountable. In contrast, 
this year NARA reported fully on the results (both negative and 
positive) of its self-assessment survey and its electronic records 
systems scheduling project. The current reports not only provide 
summary results and analysis, they also list each agency or 
component's results individually. Also, besides sending the self-
assessment report to the Congress and posting it on its Web site, NARA 
made efforts to publicize the results, including announcements through 
a press release, on Twitter, and on two blogs: those of the Archivist 
and of NARA's National Records Management Program. Further, the 
evaluation sections in NARA's performance and accountability reports 
for fiscal years 2008 and 2009 were more extensive than in 2007, and 
included sections on challenges and risks. These sections discuss 
specific agencies where NARA identified significant records management 
program risks and cases of alleged unauthorized disposition of federal 
records. By widely reporting results by agency, NARA has taken an 
important step toward improving the visibility of records management 
to senior agency managers, the Congress, and the public, potentially 
raising the priority that agencies assign to records management. 

Although instituting and reporting fully on annual self-assessment 
surveys is a positive step, the initial survey had limitations. In its 
report, NARA identified issues that it considered to affect the 
reliability and usefulness of the data in its first self-assessment 
survey. Specifically: 

* Not all regulated agencies were covered.[Footnote 33] According to 
NARA, its list of agency records contacts, to whom it sent the 
surveys, was not always accurate: the distribution list was 
incomplete, and some people included on the list were not responsible 
for their agencies' records management programs. In addition, NARA 
reported that some agencies did not return surveys because they did 
not have an assigned records management officer responsible for 
completing the task, they believed they were not required to respond, 
or for other reasons, including inadvertent oversight. 

* Another issue involves the roles of departmental and component-level 
records officers. According NARA officials, scoring was affected by 
issues related to NARA's level of knowledge of the responsibilities of 
each department-level records officer. According to NARA, agencies of 
comparable size and complexity might have one records officer 
answering on behalf of the organization, or several component-level 
records officers answering for each component.[Footnote 34] Some 
departments do not have a departmental records officer. Some 
department-level records officers responded for the entire 
organization, but, in at least one case, the department-level contact 
did not respond and deferred to the components. 

* Some questions were unclear or inapplicable. Although NARA ran a 
focus group and pilot test to obtain feedback on the survey questions, 
it reported that responses and comments indicated that the wording of 
some questions was unclear. For instance, some respondents answered 
"no" when their comments indicated they should have answered "yes," 
and vice versa. In addition, NARA found that some questions on the 
survey were not applicable to very small organizations (less than 100 
FTEs), but a "no" answer reduced their score, so that these 
organizations were penalized inappropriately in the scoring. 

NARA has taken steps to reduce the effect of these issues on the 
second survey. According to NARA officials, they gathered additional 
information on records contacts, including the areas covered by 
departmental records officers, to ensure that the survey went to the 
appropriate contacts and that NARA understood those contacts' areas of 
responsibility. In addition, the second survey included numerous 
definitions and revisions that, according to officials, were intended 
to clarify the survey. 

Another important limitation of the surveys as assessment tools is 
their reliance on unvalidated self-reported data. In the first survey 
NARA did little validation of agencies' self-reporting. According to 
NARA, its appraisal archivists[Footnote 35] reviewed the information 
provided by the agencies, and their comments were incorporated into 
the analysis. However, according to the survey report, NARA otherwise 
"took agencies at their word and did not attempt to verify 
submissions." For the second self-assessment survey (conducted in May-
June 2010), NARA asked respondents each to supply one item of 
documentation--the records management directive or directives issued 
by the department--as validation. According to officials, they 
expected to use these directives not only to validate certain 
responses, but also for analysis of features such as the age of the 
directives and extent they covered the requirements of the C.F.R. 
Officials also told us they are considering asking for additional 
documentation in future years, such as training curricula and internal 
evaluation reports. An official said that besides examining the 
directives, they validated answers for 5 of the 55 questions by 
comparing them with records schedule information that they track in-
house. 

As NARA continues to perform self-assessment surveys, it will be 
important for it to be assured that improvement (or deterioration) in 
governmentwide and agency scores reasonably reflect actual 
performance. Accordingly, validation of the results will be important 
both for the broad assessment of federal records management and for 
the assessment of individual agencies and programs. However, NARA has 
not yet developed plans to use other means of validating responses, 
such as doing followup interviews with respondents, requesting 
additional supporting documents, or including questions in the survey 
on how response data were collected. Without additional validation, 
confidence in the validity of the survey results may be reduced, and 
they may be less effective for their intended purposes. 

NARA Has Shifted Efforts from Records Management Studies to Targeted 
Inspections, but Inspection Plans Are Limited and Still Under 
Development: 

According to NARA's strategic records management plan,[Footnote 36] 
the agency is to conduct records management studies to focus on cross- 
government issues, to identify and analyze best practices, and to 
develop governmentwide recommendations and guidance. For example, NARA 
planned to undertake such studies when it believed an agency or 
agencies in a specific line of business were using records management 
practices that could benefit the rest of a specific line of business 
or the federal government as a whole.[Footnote 37] 

Since we last reported in 2008,[Footnote 38] NARA has conducted three 
records management studies (see table 3). 

Table 3: NARA Studies Performed or Planned Since 2008 GAO Report: 

Title or topic: A Report on Flexible Schedule Implementation by 
Federal Agencies; 
Date: 2008; 
Comments: Results of a survey of nine federal agencies implementing 
flexible schedules to manage the disposition of their records. 

Title or topic: Continuing Study of Federal Agency Recordkeeping 
Technologies; 
Date: 2008; 
Comments: Followup to a 2007 survey of five federal agencies 
implementing records management application (RMA) software to manage 
electronic records. The followup examined three additional agencies 
implementing RMAs and one agency implementing electronic archiving 
software for e-mail. 

Title or topic: Agency use of Web 2.0 technologies; 
Date: 2010; 
Comments: How agencies are using Web 2.0 (blogs, wikis, social 
networking sites, and other collaborative Web-based technologies) and 
perceptions of the archival value of records so created. 

Source: GAO summary of NARA information. 

[End of table] 

In accordance with its plans, all of these studies are focused on 
records management issues with wide application. In particular, 
flexible scheduling (the first study in table 3) is a relatively 
recent approach that allows so-called "big bucket" or large 
aggregation schedules (that is, a single schedule would cover all 
records relating to a work process, group of work processes, or a 
broad program area to which the same retention time would be applied). 
According to officials, NARA used the results of its study to update 
its original 2005 bulletin on this topic; the update was released in 
May 2010.[Footnote 39] In contrast, the second study in table 3 (on 
recordkeeping technologies) was not used to feed into guidance, but to 
provide helpful information to agencies: in particular, on other 
agencies' experience with implementing records management software 
and, in one case, with e-mail archiving software being implemented at 
the Office of the Secretary of Defense.[Footnote 40] The third study 
(on Web 2.0 use) was released in September 2010; according to NARA, 
the study enabled the agency to identify recommendations for future 
actions (such as clarifying the definition of a federal record and 
integrating records management into agency social media policy). 

NARA recently shifted its efforts from performing studies to 
conducting inspections. From 2005 to 2008, NARA set objectives for and 
performed one or two records management studies in each fiscal year. 
For 2010 and 2011, NARA's objectives did not include performing 
studies, but instead it set an objective to perform one inspection in 
each year. According to NARA officials, at the time the 2011 plan was 
developed, they had not determined whether to conduct a study in that 
fiscal year or do additional inspections; since then, they have 
decided to do additional inspections. 

NARA's plan to perform records management inspections in fiscal years 
2010 and 2011 reflects a resumption of NARA's agency inspection 
program in response to our 2008 recommendation. NARA describes its new 
program of inspections as taking a "targeted" approach, focusing on 
particular aspects of records management at a given agency or 
agencies. (In contrast, its previous approach involved more 
comprehensive reviews of agency records programs.)[Footnote 41] 

To set up the inspection program, NARA took a number of steps: it 
revised its requirements, developed criteria for doing inspections, 
chose its first inspection targets, and has begun performing 
inspections. NARA added a new section of its regulations[Footnote 42] 
that defines the conditions under which it may undertake an inspection 
and how the inspection will be initiated and carried out with the 
agency. Under the final rule, published on October 2, 2009, 
"inspection" is defined as a formal review and report by NARA of an 
agency's recordkeeping processes that focus on significant records 
management problems affecting records at risk that meet one or more of 
the following criteria: (1) they have a direct and high impact on 
legal rights or government accountability; (2) they are the subject of 
high-profile litigation, congressional attention, or widespread media 
coverage; (3) they have high research potential; or (4) they are 
permanent records with a large volume, regardless of format. 

For fiscal year 2010, NARA chose to perform two inspections, both at 
the Department of Defense: an inspection at the Office of the 
Secretary of Defense (OSD) looking at three aspects of records 
management and one at the National Geospatial-Intelligence Agency 
(NGA). According to a NARA official, the inspection at the NGA, 
planned to begin in 2010, will not be completed until 2011. Table 4 
describes these inspections. 

Table 4: Inspections Performed or Planned: 

Inspected entity: OSD; 
Subject of inspection: Executive Archives Project: Process for 
reviewing paper files of high-level officials, screening out temporary 
materials, and scanning records to facilitate access and retrieval. 
Main focus is to ensure that screening was appropriate and did not put 
permanent records at risk; 
Status: Performed 3rd quarter 2010. 

Inspected entity: OSD; 
Subject of inspection: Recordkeeping practices of the Under Secretary 
for Intelligence: Focus on whether records are covered by approved 
schedules and maintained to ensure effective retrieval and disposition; 
Status: Performed 3rd quarter 2010. 

Inspected entity: OSD; 
Subject of inspection: E-mail archiving system: Focus on recordkeeping 
copies of non-transitory e-mail and OSD's planned disposition of e-
mail messages in the system; 
Status: Performed 3rd quarter 2010. 

Inspected entity: NGA; 
Subject of inspection: Transfer to NARA of finished mapping products 
(both hard copy and electronic), such as maps, nautical charts, and 
other materials, as well as related documents accumulated in the 
course of preparing maps (according to an agency official); 
Status: To be completed in fiscal year 2011 (according to an agency 
official). 

Source: GAO analysis of NARA information. 

[End of table] 

At the time of our engagement, NARA had not issued planned reports on 
the results of the OSD inspections, and, according to an agency 
official, planning for the inspection at NGA was still in an early 
stage. 

Resuming inspections is an important step, because inspections provide 
information in more detail on actual performance and particular 
records issues; however, the inspection program currently planned is 
limited. NARA's plan commits to conducting one inspection per year for 
fiscal years 2010 and 2011, and officials told us they were 
considering one or two inspections per year. According to one NARA 
official, NARA is unwilling to commit to more inspections because it 
has other priorities for the appraisal archivist staff, which also 
performs appraisals and scheduling, conducts studies, and works on the 
self-assessment survey and other special projects. (According to a 
NARA records management official, of the 100 staff of the National 
Records Management Program, approximately 50 are appraisal archivists, 
who work with about 245 agencies or components.) 

NARA's planning for its inspection program is at a high level and is 
still under development. According to its 2009 methodology for self- 
assessments and inspections, NARA will develop a list of agency 
inspection targets based partially on the self-assessment results, 
develop inspection plans, and conduct inspections.[Footnote 43] The 
plan identifies 20 conditions that the records management staff is to 
consider to help determine whether an agency may be an inspection 
candidate. (Examples include nonresponses to NARA's surveys, out-of- 
date agency records management manuals, requests from an agency head, 
and unresolved unauthorized destructions.) These are conditions that 
management is to assess in making inspection decisions--a checklist of 
risk factors to consider. According to agency officials, they expect 
to flesh out the inspection methodology as they gain experience doing 
their first targeted inspections in fiscal years 2010 and 2011. 

However, the 2009 methodology does not define how NARA will 
systematically target and leverage a limited number of inspections to 
help achieve governmentwide results (one of its stated goals). For 
example, the agency has not yet described how it might distribute 
inspections among agencies or what topics it would like to cover over 
a period of years. Similarly, although NARA plans to perform multi-
agency inspections, it has not yet developed plans to do so by, for 
example, defining key practices and determining how to inspect these 
at multiple sites. NARA's plan states that self-assessment and 
inspection activities will help NARA monitor how federal agencies 
manage their records, but it does not address how one or two 
inspections a year would provide effective monitoring or how it would 
best organize a limited number of inspections to accomplish this goal. 

NARA activities alone cannot solve the persistent problems facing 
federal records management, since agency heads are responsible for 
their agencies' records and records management, as well as for 
allocating resources to these, and as we have pointed out in the past, 
records management has historically received low priority. 
Nonetheless, shedding light on the status of governmentwide records 
management can help focus both agencies and NARA on areas needing 
improvement and the need to devote resources to these areas. NARA's 
renewed inspection program has the potential not only to help motivate 
agencies to improve records management, but also to contribute to the 
systematic collection of comprehensive information for assessing 
progress. However, NARA's plans do not explain how it will 
systematically target and leverage a limited number of inspections to 
help achieve its goals. Until it has a more fully developed inspection 
methodology, NARA risks reducing the potential effectiveness of 
inspections for improving records management. 

NARA Is Addressing the Problem of Unscheduled Records, but Faces 
Backlogs in Approving Schedules: 

NARA oversees retention and disposition of all federal records through 
records appraisal and approval of agency records schedules, processes 
that are crucial both to the management of records in agency custody 
and to the eventual preservation of permanent records in NARA's 
custody. NARA's authority to approve disposition schedules provides it 
with the ability to ensure that such schedules conform to its 
regulations.[Footnote 44] NARA has identified unscheduled records as 
an important indicator of the risk of unauthorized destruction of 
records. 

NARA has been making efforts to get agencies to schedule unscheduled 
records in computer systems. This project, which it refers to as the 
Electronic Records Project, was initiated in response to the 
requirements of the E-Government Act.[Footnote 45] In December 2005 
NARA issued a bulletin requiring agencies by September 30, 2009, 
[Footnote 46] to submit records schedules to NARA for all electronic 
systems of records existing as of December 17, 2005, and it has 
periodically requested agencies to provide summary reports documenting 
their progress.[Footnote 47] After the 2009 deadline expired, NARA 
issued, in February 2010,[Footnote 48] an additional bulletin 
reminding agencies of their continuing responsibility to schedule all 
their electronic records series and systems and requiring them to 
report semiannually on the status of their electronic records 
scheduling activities. 

In fiscal year 2009, the number of schedules received jumped from 549 
the previous year to 974, which NARA attributes to its efforts to hold 
agencies to the September 2009 deadline. Although this result is 
encouraging, it also led to an increase in NARA's backlog of schedules 
to be processed and approved. The number of schedules submitted 
increased by more than 400, while the number closed out increased by 
only about 100, from 402 to 501; as a result, the approval backlog 
increased from 575 to 1048. NARA's processing capacity reached a high 
of 501 schedules closed out in 2009, so the current backlog represents 
about 2 years' work for appraisal staff, assuming that they go on 
approving schedules at the current rate, and that no other schedules 
are submitted in the meantime. 

NARA's schedule approval process occurs in four steps (see table 5) 
involving professional analysis and judgment, as well as input from 
the public. 

Table 5: Review Process for Records Schedules: 

Step: Schedule is received and initially checked; 
Process: Schedule is assigned to an appraisal archivist for initial 
review.; Schedules must include, for example,; clear descriptions of 
the records at the series or system level and; clear and readily 
applicable cut-off and disposition instructions. 

Step: Schedule is reviewed for appropriateness; 
Process: Appraisal archivists review schedules and often the records 
concerned to determine whether proposed disposition instructions are 
appropriate: 
* Records proposed for permanent retention warrant preservation in the 
National Archives; 
* Files proposed for disposal lack historical or other research value; 
* Retention periods proposed for temporary records are long enough to 
protect the legal rights of the government and private parties. 

Step: Schedules are posted for public comment; 
Process: NARA is required by law to publish notice in the Federal 
Register of schedules proposing: 
* the disposal of unscheduled series of records or; 
* a reduction in the retention period of a series already approved for 
disposal. 
Public comments may be submitted for 30 days. During this time, 
members of the public can request copies of schedules and appraisal 
reports; they then have 30 additional days to submit responses. 

Step: Issues are resolved; 
Process: Issues may be raised by review of the schedule or the records 
it includes and by input from other NARA units or the public. 
Revisions may involve changes in the disposition of a series (from 
temporary to permanent or vice versa) or modifications in the 
retention period for a temporary series. After NARA and the agency 
resolve issues, the schedule is approved and sent to the agency for 
implementation. 

Source: GAO analysis of NARA information. 

[End of table] 

NARA estimates that it generally takes approximately 6 months or less 
to process simple schedules for records that are clearly temporary and 
do not have legal rights implications, with almost 4 months of this 
time period taken by the public comment process. It may take up to a 
year for NARA to process large and complex schedules requiring closer 
review or eliciting critical public comments. According to NARA, the 
median time for it to approve a schedule has historically been about 
300 calendar days. 

NARA is trying to shorten its approval process and increase its 
capacity to process schedules despite limited resources. It has about 
100 people working on records management, about half of whom work on 
appraisal and scheduling. The director of the Lifecycle Management 
Division (within Modern Records Programs) said the records management 
program aimed to increase approvals of records schedules covering 
electronic records by about 10 percent a year, and that staff are 
working on streamlining the scheduling process. For example, the 
program has reduced the time allowed for public comment by 15 days, 
and staff are using e-mail rather than letters to communicate and send 
responses to requests from Federal Register requesters. The official 
also described future projects, including a project to improve the 
scheduling and appraisal workflow and a large project to revise the 
General Records Schedules, which should have the effect of reducing 
the number of schedules that agencies will have to submit, thereby 
improving NARA's ability to keep up with other submitted schedules. 

Although these efforts may help to streamline the process, the number 
of records and systems that remain to be scheduled is likely very 
large. Currently, the Director of Lifecycle Management said that they 
are unable to estimate "the universe of electronic records," although 
they are confident that it is a "big number." For example, in 2006, 
NARA requested information from agencies on outstanding systems to be 
scheduled and received answers from 54 agencies, for a total of about 
8,500 systems. 

Other indications also support the conclusion that many records remain 
unscheduled. For example, NARA's electronic records summary report 
indicated that many electronic records were still unscheduled. As of 
September 30, 2009, based on 240 federal agencies and components: 

* For 14 percent of agencies, schedules were submitted for 59 percent 
or fewer of their e-records (these were characterized as high risk). 

* For 11 percent of agencies, schedules were submitted for 60 to 89 
percent of their e-records (these were characterized as moderate risk). 

* For 42 percent of agencies, schedules were submitted for 90 percent 
of more of their e-records (these were characterized as low risk). 

* 33 percent of agencies did not submit reports. 

Further, NARA's agency self-assessment indicated that 27 percent of 
agencies responding had scheduled fewer than half of their electronic 
systems. The survey did not ask for the numbers of systems remaining 
unscheduled; however, NARA's February 2010 bulletin requires agencies 
to list unscheduled systems. As agencies comply with this requirement, 
such lists should provide a basis for a better estimate. 

NARA thus faces the risk that if its efforts to get agencies to submit 
schedules for outstanding agency systems continue to be successful, it 
will be unprepared to deal with the workload. The jump in its backlog 
associated with the 2009 deadline for scheduling electronic systems 
suggests that this is a real concern. NARA has acknowledged that in 
light of the volume and complexity of electronic records increasing 
each year, keeping pace with the requirements to schedule all existing 
electronic records is a continuing challenge for both NARA and 
agencies.[Footnote 49] However, it has not assessed the risk that it 
may be unable to keep up with schedules submitted, nor has it 
developed plans to mitigate that risk. Unless it does so, the risk 
increases that the backlog may increasingly hinder agencies' records 
management--for example, they may be required to retain records 
unnecessarily that they would otherwise be authorized to dispose of, 
and they may be delayed in transferring permanent records to NARA. 

NARA's Ability to Preserve Federal Records Is Strained by Volume of 
Records, Finite Resources, and Technology: 

NARA faces challenges in preserving permanent records in its 
possession--both paper and electronic--largely because of the sheer 
volume of federal records, the finite resources available to deal with 
them, and the technological challenges posed by electronic records. 
NARA has a large and persistent backlog of records in paper and other 
media needing preservation actions. It has developed priorities for 
preserving physical records based on factors such as their demand and 
condition, but it does not foresee being able to accomplish those 
priorities. As a result, large numbers of physical records requiring 
preservation remain at risk. In addition, as we have previously 
reported, its development of the Electronic Records Archives is still 
ongoing, including the development of a preservation framework for 
electronic records. Until ERA and its electronic preservation 
capabilities are fully implemented, there is reduced assurance that 
NARA can ensure the preservation of all electronic records. 

The Volume of Physical Records Needing Preservation Actions Has Led to 
Large Backlogs: 

According to NARA, preservation encompasses the activities that 
prolong the usable life of archival records. Preservation activities 
are designed to minimize the physical and chemical deterioration of 
records and to prevent the loss of informational content.[Footnote 50] 
For physical records, an important part of preservation is holdings 
maintenance, defined as those preservation actions that are designed 
to prolong the useful life of records and to reduce or defer the need 
for laboratory treatment by improving the physical storage 
environment. These actions include replacing acidic storage materials 
such as file folders with materials of known quality that meet NARA 
specifications, improving shelving practices, removing damaging 
fasteners, and reproducing unstable materials such as Thermofax copies 
onto stable replacement materials. In addition, preservation may 
involve removing fragile records from use by capturing the information 
in a new format. NARA may duplicate motion picture film, still photos, 
microfilm, and sound and video recordings; reformat audio and video 
recordings that are in formats that cannot be used on currently 
available playback equipment; and generate digital images of records. 

NARA's approach to preserving physical records and media (such as 
paper records, videotapes, microfilm, maps, charts, and artifacts) is 
to examine holdings to assess their preservation needs; provide 
storage conditions that retard deterioration; and treat, duplicate, or 
reformat records at high risk for loss or deterioration (for example, 
film and microfilm, audio recordings that require obsolete equipment, 
videos, brittle and damaged paper records, and motion pictures). Some 
of the factors influencing the rate at which NARA performs maintenance 
and preservation treatments, according to the agency, include large 
accessions of at-risk records, increased demand for the digitization 
of records, and high public interest. 

The number of physical records requiring some degree of preservation 
activity has led to a backlog in preservation actions. In 2009, NARA 
reported that 65 percent[Footnote 51] of its archival holdings were in 
need of some preservation action.[Footnote 52] NARA defined "in need 
of preservation action" as that there was an imminent threat to the 
record, and the information it contained could not be accessed due to 
condition. According to NARA, it was conservative in this assessment, 
focusing on whether records could be safely served to researchers in 
their existing state and housing. For example, even though poor 
quality, chemically unstable boxes are not ideal for archival 
preservation, they would not be considered to require preservation 
action (that is, replacement); however, a box that did not adequately 
support the records would, since records that are not well supported 
are likely to be damaged. 

NARA has set a strategic goal of reducing the backlog to 50 percent by 
2016. However, there is little assurance the goal will be met. The 65 
percent figure has remained almost constant since NARA established a 
baseline. In fiscal year 2009, NARA reported treating nearly 116,000 
cubic feet of at-risk archival records. Nonetheless, as additional 
records were accessioned, the percentage of backlog remained 
essentially constant, and the actual amount of holdings requiring 
preservation action grew from about 2.4 million cubic feet in 2008 to 
about 2.6 million cubic feet in 2009. Further, in its 2008 
preservation plan for nontextual holdings (maps, photos, audio, and 
video), NARA noted that 54,000 cubic feet of these records needed 
preservation actions, and that even addressing only the highest 
priority items (about 25 percent) exceeded its staff resource 
capabilities. 

Over the past year, NARA increased the staff performing holdings 
maintenance (preservation activities such as rehousing at-risk 
materials) from about 8 to 18 dedicated staff (according to officials, 
some additional staff also devote part of their time to holdings 
maintenance). Nonetheless, there is little assurance that NARA will be 
able to meet its goal of reducing the backlog to 50 percent by 2016, 
and in any case, large numbers of permanent records will remain at 
risk for the foreseeable future. 

Electronic Records Preservation Will Remain a Challenge: 

Preservation of electronic records presents significant challenges 
because these records are stored in specific formats and cannot be 
read without software and hardware--sometimes the specific types of 
hardware and software on which they were created. This hardware and 
software can vary not only by type but by generation of technology: 
the mainframe, the personal computer, and the Internet. Each 
generation of technology has brought in new systems and capabilities, 
and over time, hardware, software, storage media, and file formats 
become obsolete. 

NARA is still developing the means to preserve permanent electronic 
records--the Electronic Records Archives. ERA achieved initial 
operational capability of the first two phases of the five-phase 
development, but the preservation component of the project is still 
being developed. The former CIO told us that in her view, the 
preservation module would be the most difficult to implement of the 
system's functional areas.[Footnote 53] This module is to enable 
secure and reliable storage of files in formats in which they were 
received, as well as creating backup copies for off-site storage. 

Part of the preservation challenge is developing ways to ensure access 
to the most important formats, which NARA intends to do through 
various means, such as encouraging the use of sustainable formats and 
using viewers and transformation.[Footnote 54] According to the 
conceptual framework for ERA preservation, NARA will encourage 
creating entities to transfer records to NARA using sustainable 
formats--that is, formats that are relatively resistant to 
obsolescence and can reasonably be expected to be usable for some 
period of time.[Footnote 55] However, the framework recognizes that in 
many cases, this will not happen, and so ERA will need to ingest a 
broad range of formats. After files are ingested, the intent is to 
transform records as necessary into formats that are sustainable. 
Since transformation is the most expensive strategy for providing 
access to records, NARA plans to consider transforming electronic 
records only if the data file format is at risk of obsolescence, users 
require an enhanced level of access, or both. NARA expects to be able 
to preserve "all the bits" of electronic files that it accessions, but 
it will not be able to guarantee that all formats will be immediately 
or permanently accessible. 

Further, we recently reported[Footnote 56] that NARA planned to begin 
development of ERA's preservation framework in 2010 and complete it in 
2011, but that the plan did not contain specific dates for completion 
or identify the associated capabilities that are to be delivered. As a 
result, we expressed doubt that the completed ERA system would be 
delivered by 2012 with the originally envisioned capabilities. Most 
recently, ERA has been listed by OMB as a high-priority project that 
has the potential for faster, smarter implementation.[Footnote 57] 
Properly implementing our outstanding recommendations related to 
strengthening requirements management[Footnote 58] and earned value 
management[Footnote 59] could help the ERA project meet its 
performance goals within reasonable funding and time constraints. 
Until ERA and its preservation module are complete, it will remain 
uncertain whether NARA will be able to effectively preserve all 
permanent electronic records in such a way that the information is 
accessible. 

In Key Management Areas, NARA Has Policies and Procedures that Are 
Consistent with Its Strategic Planning, although Gaps Remain: 

NARA's policies and procedures for key aspects of governance, human 
capital, and collaboration are generally aligned with its strategic 
planning, but selected areas have gaps. With regard to governance 
policies and procedures, NARA has defined and delegated areas of 
authority and responsibility that are generally aligned with its 
strategic plan, but it is not managing risk at the enterprise level. 
In addition, it has developed a strategic human capital plan that is 
consistent with our human capital strategic framework, but its 
implementation of the plan has been delayed, so that the agency is not 
yet managing human capital strategically. To its credit, NARA is 
taking advantage of numerous collaboration opportunities, which are 
generally aligned with the goals and strategies in its strategic plan. 
If NARA addresses the identified gaps in governance and human capital, 
it will be better positioned to achieve its goals. 

NARA Has Policies and Procedures Defining Key Aspects of Governance, 
but It Lacks an Enterprise Risk Management Capability: 

We have previously described governance as the process of providing 
leadership, direction, and accountability in fulfilling an 
organization's mission, meeting objectives, and establishing clear 
lines of responsibility for results. Further, our prior work has 
established that enterprisewide risk assessment and management is a 
key part of governance.[Footnote 60] 

NARA's Lines of Responsibility Are Generally Aligned with Its 
Strategic Planning: 

Strategic planning and management can help agencies effectively manage 
resources and fulfill their missions, and, since the mid-1990s, we 
have reported on leading practices for effective strategic planning 
and management, including establishing long-term goals, identifying 
and developing strategies to address key management challenges, and 
aligning resources and activities to agency goals. 

NARA has a strategic plan and a process for aligning its organization 
and lines of responsibility to support its goals. The agency's 
recently updated strategic plan[Footnote 61] governs its activities 
until 2016 and details six strategic goals (see table 6) and 46 
specific strategies it will use to achieve these goals. 

Table 6: NARA's Strategic Goals: 

Short title: The nation's record keeper; 
Strategic goal: Ensure the continuity and effective operation of 
federal programs by expanding leadership and services in managing 
records. 

Short title: Preserve and process; 
Strategic goal: Preserve and process records to ensure access by the 
public as soon as legally possible. 

Short title: Electronic records; 
Strategic goal: Address the challenges of electronic records in 
government to ensure success in fulfilling NARA's mission in the 
digital era. 

Short title: Access; 
Strategic goal: Provide prompt, easy, and secure access to holdings 
anywhere, anytime. 

Short title: Civic literacy; 
Strategic goal: Increase access to records in ways that further civic 
literacy in America through museum, public outreach, education, and 
grants programs. 

Short title: Infrastructure; 
Strategic goal: Equip NARA to meet the changing needs of customers. 

Source: GAO analysis of NARA data. 

[End of table] 

Specific strategies support each of these goals. These strategies 
include, for example, 

* "we will continue to make the business case at senior levels 
throughout the Federal Government that records and information are 
important Government assets and that records management is an 
important tool," 

* "we will ensure that all of our holdings are in appropriate space," 

* "we will identify permanently valuable electronic records wherever 
they are, capture them, and make them available in usable form as 
quickly as practical" and: 

* "we will identify and implement the cultural changes that we need to 
better serve our customers in a changing environment." 

NARA has also established policies and procedures that define its 
organization and determine lines of authority and areas of 
responsibility. Responsibilities at the agency are approved by the 
Archivist through a defined process and are codified, along with the 
change process, in NARA Directive 101: NARA Organization and 
Delegation of Authority. For tasks that cut across organizational 
structures, NARA has procedures for setting up committees, task 
forces, and working groups, which are governed by charters 
establishing their goals and membership. It has a directive governing 
creation of these charters. 

Generally, NARA's organization and lines of responsibility were 
aligned with its strategic plan. Of 21 specific strategies that we 
examined, 17 were under clearly documented lines of authority and were 
assigned to appropriate offices by the agency's policies, with 4 
strategies lacking clearly documented lines of responsibility (see 
table 7). 

Table 7: Strategies Lacking Clear Lines of Responsibility: 

Goal: Address the challenges of electronic records in government to 
ensure success in fulfilling NARA's mission in the digital era; 
Strategy: 
* Develop, implement, integrate, and manage an electronic records 
program, which is responsive to the needs of the Federal Government 
and our customers who expect continuing access to our Government's 
electronic records. 

Goal: Equip NARA to meet the changing needs of customers; 
Strategy: 
* Identify and implement the cultural changes that we need to better 
serve our customers in a changing environment; 
* Increase staff productivity by improving our systems and processes; 
* Involve employees in defining the best practices for their unit. 

Source: GAO analysis of NARA data. 

[End of table] 

According to NARA officials, they did not consider that some of these 
strategies required specific assignments of responsibility, either 
because they were global responsibilities or because they were good 
business practices. However, clear statements of responsibility are 
important for implementing these strategies. We have previously 
reported that a dedicated implementation team assisted by supporting 
teams, such as functional or crosscutting teams, is a key practice in 
implementing cultural transformations.[Footnote 62] Assigning 
responsibility for these strategies to appropriate offices would help 
to provide assurance that they are appropriately carried out. 

NARA Does Not Manage Enterprise Risk on a Continuous Basis: 

Enterprisewide risks are those that would threaten an organization's 
ability to carry out its mission, such as an act of terrorism, loss or 
compromise of critical information (such as classified or personally 
identifiable information), or a natural disaster. Risk management is 
the continuous process of assessing such risks, reducing the potential 
that an adverse event will occur, and putting steps in place to deal 
with any event that does occur. Without an effective program of risk 
assessment and internal control, management may have less assurance 
that it is using organizational resources effectively and efficiently, 
or that agency assets and operations are protected. As our previous 
work has shown,[Footnote 63] and as called for by the Standards for 
Internal Control in the Federal Government,[Footnote 64] agencies 
should continuously and systematically monitor their internal and 
external environments to anticipate future challenges and avoid 
potential crises.[Footnote 65] 

GAO has developed a framework for risk management (see figure 3) that 
identifies five major phases: (1) setting strategic goals and 
objectives, and determining constraints; (2) assessing the risks; (3) 
evaluating alternatives for addressing these risks; (4) selecting the 
appropriate alternatives; and (5) implementing the alternatives and 
monitoring the progress made and results achieved. 

Figure 3: GAO Risk Management Framework: 

[Refer to PDF for image: illustration] 

Interdependent, interlocking circular illustration: 

Strategic Goals, Objectives, and Constraints: 
Risk Assessment: 
Alternatives Evaluation: 
Management Selection: 
Implementation and Monitoring: 

Source GA. 

[End of figure] 

Our work has shown that decisions for enterprisewide risk management 
should be made in the context of an organization's strategic plan, and 
organizations should have risk planning documents that address risk-
related issues that are central to the organization's mission. 

According to NARA program officials, NARA currently performs risk 
management for the ERA project, its major system investment. The 
agency manages ERA's risks using an agency-level risk review board, a 
program-level risk review board, and a technical risk review team. In 
addition, officials stated that the ERA program office produces 
monthly reports that include top identified risks and specify 
associated mitigation strategies. Risk status is communicated to 
senior NARA management and OMB on a monthly basis and Congress on a 
quarterly basis. The project uses an automated tool to track and 
manage risk. 

However, although NARA has identified important risks facing the 
agency, it currently has no dedicated active function to manage these 
risks at the enterprise level. Some risks of which NARA is aware 
include: 

* technological change causing record formats to become obsolete and 
unreadable, 

* failure of the ERA project, and: 

* effects of climate change or natural disasters (such as on 
continuity of operation, preservation requirements, locations of 
facilities, and energy use). 

According to NARA officials, the organization had a risk review board, 
which existed for about 2 years, but it became inactive. This occurred 
because the board's discussion of risk tended to focus either on 
project and program risks or highly generic risks. 

NARA officials told us that the agency has also relied on a work group 
of senior executives, the Lifecycle Guidance Team, to address 
enterprisewide risks. However, as currently established, the Lifecycle 
Guidance Team does not explicitly focus on enterprise risk management. 
The members of this team, chaired by the Deputy Archivist, are members 
of NARA's senior staff.[Footnote 66] However, although the team is at 
an appropriate level of seniority to address enterprise risk 
management, this function is not part of its charter. According to the 
charter, the group focuses on ensuring that NARA's records lifecycle 
initiatives are effectively coordinated, integrated, and implemented 
agencywide, and it provides leadership and oversight to initiatives to 
advance the agency's mission and strategic goals and improve records, 
information, and knowledge management governmentwide. Among the 
initiatives it is reviewing or has reviewed are systems in operation 
or in development, for which project risks have been discussed. 
However, these risks are not enterprise risks. 

According to NARA officials, the development of a new process and 
system for internal control has recently been proposed. The process 
and system, to be based on a similar system at the Library of 
Congress, are intended to automate internal controls and would include 
assessment and categorization of risk on the functional level. 
According to the officials, such an implementation would benefit 
NARA's risk management and internal control capabilities. This 
proposal has been reviewed by senior management, but is still in the 
first stages of planning and does not yet include a clear picture of 
which divisions will be responsible for dealing with strategic risks. 
At the time of our report, agency officials also acknowledged that 
NARA has neither completed a time frame for implementation nor 
established an estimated finish date. 

Unless NARA begins to manage its enterprise risks on a continuous 
basis, there is a greater likelihood that serious threats to NARA may 
not be addressed. 

NARA Is Addressing Human Capital Issues, but Implementation of 
Strategic Human Capital Management Is Only Beginning: 

The success of any organization depends on effectively leveraging 
people, processes, and tools to achieve defined outcomes and results. 
For people to be effectively leveraged, they must be treated as 
strategic assets. An agency's strategic human capital plan establishes 
an agencywide vision that guides workforce planning and investment 
activities. 

As our previous work has shown, a strategic approach to human capital 
management enables an organization to be aware of and prepared for its 
current and future human capital needs, such as workforce size, 
knowledge, skills, and training. Sound human capital strategic 
planning provides the essential context for making sensible, fact-
based choices about designing, implementing, and evaluating human 
capital approaches.[Footnote 67] It is critical to ensuring that 
agencies have the talent and skill mix they need to address their 
current and emerging human capital challenges.[Footnote 68] 

Our research shows that to be effective, a strategic approach should 
use data-driven methods to (1) assess the knowledge and skills needed; 
(2) inventory existing staff knowledge and skills; (3) forecast the 
knowledge and skills needed over time; (4) analyze the gaps in 
capabilities between the existing staff and future workforce needs, 
including consideration of evolving program and succession needs 
caused by turnover and retirement; and (5) formulate strategies for 
filling expected gaps, including training and additional hiring. 
[Footnote 69] (Figure 4 is an overview of this process.) 

Figure 4: Overview of Strategic Approach to Human Capital Management: 

[Refer to PDF for image: illustration] 

Organizational Mission: 

Organizational goals and execution: 
Forecast of future workforce needs: 
Gap analysis: 
Initiatives to address capability gap; 
Inventory of existing workforce capabilities. 

Source: GAO. 

[End of figure] 

In August 2009, NARA published its first Strategic Human Capital Plan, 
which covers fiscal years 2009 through 2014. Linked to the agency's 
overall strategic plan, this strategic plan discusses strategies for 
achieving each of its five human capital goals: strategic alignment, 
leadership and knowledge management, results-oriented performance 
culture, talent management, and accountability. 

The strategic plan includes a set of improvements that would give NARA 
the capability to strategically manage its human capital, as called 
for in our human capital framework. Specifically, section 3, 
"Workforce Planning," includes all five of the elements of our 
strategic human capital framework. The plan also includes related 
goals, such as being able to hire people faster by automating manual 
and paper-based processes; NARA's Director of Human Resources cited 
this as one of the agency's highest priorities. 

The agency has taken some initial steps to implement its plan. For 
example, it has completed a pilot of a competency development approach 
in which it modeled the competencies required for all positions in the 
Modern Records Program and in the Information Security Oversight 
Office; it is currently assessing the accuracy and effectiveness of 
the competency models developed under the pilot. Modeling 
competencies--determining the skills needed for specific positions--is 
a key tool for determining what skills NARA will need to meet 
organizational goals. Once competency modeling is completed, NARA will 
be in a position to forecast future workforce skills needs. It is also 
currently finalizing guidance for workforce planning, another part of 
the process of forecasting future workforce needs. Finally, it has 
completed a pilot for an online training needs assessment tool. The 
results are currently being analyzed, and a report is tentatively 
scheduled for September. 

However, NARA is falling behind in the implementation of its human 
capital management milestones. For fiscal year 2010, NARA set 72 
milestones for implementing the strategic plan. However, as of the end 
of the third quarter, 23 milestones had been met, 14 were missed, 3 
future milestones were pushed further back, and 8 had other 
weaknesses, such as lacking a specific date or status update. Of the 
remaining 24, some are not due yet, and some were periodic actions 
with no single due date (see figure 5). An example of a missed 
milestone specifically related to our strategic human capital 
framework is the development of an agencywide workforce plan that 
includes a hiring projections worksheet. In addition, NARA has not 
completed an inventory of existing workforce skills. Without a 
complete skills needs forecast and a current skills inventory, it 
cannot perform a gap analysis and consequently cannot plan future 
human capital initiatives, three of the steps of our strategic human 
capital framework. 

Figure 5: Status of Human Capital Strategic Plan Milestones: 

[Refer to PDF for image: pie-chart] 

Completed: 23; 
Not yet due (4th quarter milestones): 19; 
Not applicable[A]: 5; 
Not yet missed but pushed back: 3; 
No date specified for completion: 3; 
No status update provided: 5; 
Missed: 14. 

Source: GAO analysis. 

[A] Monthly and quarterly tasks with multiple milestones. 

[End of figure] 

The agency's human capital officials stated that milestones had been 
missed or pushed back because they had to address other priorities, 
including realigning staff to address the requirement to comply with 
the Office of Personnel Management's (OPM) 2009 Hiring Reform and the 
May 2010 Presidential Hiring Reform Initiatives. 

To its credit, in responding to these initiatives, NARA is making 
progress on addressing its hiring process. Hiring is an important part 
of strategic human capital management, since hiring is a critical tool 
for addressing skills gaps. According to NARA, as of September 2009, 
it had an overall average time to fill a position of 163 to 213 days. 
In contrast, the model set up by OPM called for an 80-day hiring 
process. Responding to OPM's 2009 Hiring Reform,[Footnote 70] NARA's 
Hiring Process Action Plan (submitted to OPM in December 2009) 
identified primary barriers to a timely and effective hiring process. 
According to the plan, an important barrier was the agency's paper-
based application process, including manual routing of forms. During 
NARA's hiring process, its staff manually printed, reviewed, and 
annotated hundreds of applications at several stages in order to 
verify and screen applications. The agency also experienced a 45 to 90 
day backlog of hiring actions, which NARA officials attributed largely 
to reliance on paper-based hiring systems. NARA determined that 
without an automated staffing system to screen applications, 
addressing the other barriers identified in its action plan would have 
only a marginal impact on its overall time to fill a position. 

To address this barrier, NARA piloted and implemented automated hiring 
software, called USA Staffing, provided by OPM. This Web-based system 
automates the recruitment, assessment, referral, and notification 
processes,[Footnote 71] reducing the degree of human intervention 
required in the hiring process. According to NARA, the agency 
implemented the USA Staffing tool in May 2010, and as of July 2010, it 
reported reducing the average time-to-hire to 126.5 days. Agency human 
capital officials told us they believed further reductions were likely 
as the staff becomes more familiar with the new tool. 

NARA continues to work on its hiring process in response to the May 
2010 Presidential Hiring Reform Initiative, which set a deadline of 
November 1, 2010, for federal agencies to adopt certain streamlined 
hiring procedures, including eliminating knowledge, skills, and 
abilities (KSA) essays, allowing applicants to apply using resumes and 
cover letters, and involving the managers and supervisors responsible 
for hiring in the complete hiring process. 

Agency human capital officials believe that these improvements will 
result in a more efficient hiring process. However, the reforms under 
the Presidential Initiative are still ongoing. Further, because the 
adoption of the new staffing system is still recent, it is not 
possible to fully evaluate its impact. 

In addition, for the hiring process to be fully effective, it is 
important that NARA implement its strategic human capital plan and 
particularly that it complete its skills needs analysis and gap 
analysis. Such analyses are crucial for effectively determining hiring 
needs; they are also important for helping determine how to allocate 
personnel to mission areas in which NARA has identified resource- 
related backlogs, such as records management and preservation. Until 
NARA completes these analyses, there is no assurance that the agency 
will be able to manage its human capital strategically, ensuring that 
it has staff with the right competencies to perform its mission now 
and in the future. 

NARA Engages in Collaborative Efforts That Further Strategic Goals: 

As a small agency with a broad mission, NARA has stressed the 
importance of collaborative efforts in achieving the organization's 
goals. In his preface to the agency's strategic plan, the Archivist 
refers to the importance of involvement with the archival and records 
management communities as well as other stakeholders, stating that 
partnerships at all levels of the organization will add depth and 
richness to NARA's programs and initiatives. The strategic plan itself 
emphasizes collaboration and partnering. It spells out six strategic 
goals, for each of which the plan describes a number of specific 
strategies. For five of the six goals in the strategic plan, either 
one or two of the specific strategies are directly related to 
collaboration and partnership; table 8 shows the specific strategies 
associated with each strategic goal. 

Table 8: NARA's Strategic Goals and Collaboration Strategies: 

Short title: The nation's record keeper; 
Strategic goal: Ensure the continuity and effective operation of 
federal programs by expanding leadership and services in managing 
records; 
Specific strategies related to collaboration and partnership: Work 
with industry and academic experts to develop automated records 
management solutions. 

Short title: Preserve and process; 
Strategic goal: Preserve and process records to ensure access by the 
public as soon as legally possible; 
Specific strategies related to collaboration and partnership: (No 
specific collaboration strategy). 

Short title: Electronic records; 
Strategic goal: Address the challenges of electronic records in 
government to ensure success in fulfilling NARA's mission in the 
digital era; 
Specific strategies related to collaboration and partnership: Partner 
with agencies, research institutions, and private industry to develop, 
implement, manage, and promote NARA's electronic records program. 

Short title: Access; 
Strategic goal: Provide prompt, easy, and secure access to holdings 
anywhere, anytime; 
Specific strategies related to collaboration and partnership: Partner 
with both governmental and private institutions to facilitate the 
availability of NARA holdings over the Internet, while ensuring that 
NARA obtains ownership of the digital versions. 

Short title: Civic literacy; 
Strategic goal: Increase access to records in ways that further civic 
literacy in America through museum, public outreach, education, and 
grants programs; 
Specific strategies related to collaboration and partnership: Partner 
with industry, national and international institutions, and affiliated 
archives to develop cooperative initiatives that showcase NARA 
holdings, promote civic and historical literacy, and highlight the 
importance of records. 

Short title: Infrastructure; 
Strategic goal: Equip NARA to meet the changing needs of customers.; 
Expand partnerships with the professional communities who share NARA's 
goals and mission; 
Specific strategies related to collaboration and partnership: Continue 
to partner with the private foundations that support the National 
Archives and the presidential libraries to increase customers and 
produce quality products and services of interest to the public. 

Source: GAO analysis of NARA data. 

[End of table] 

NARA has established or begun to establish collaborative efforts that 
are generally aligned with all these goals and strategies. For 
example, for the third strategic goal, which focuses specifically on 
electronic records, the specific strategy related to collaboration is 
to partner with agencies, research institutions, and private industry 
to develop, implement, manage, and promote NARA's electronic records 
program. According to its workplan, multiple efforts in this area are 
planned to be managed by NARA's Center for Advanced Systems and 
Technologies (NCAST) within the Office of Information Services. NCAST 
serves as lead for collaborating in information technology research 
and development with governmentwide, interagency, professional, and 
academic organizations. Among other things, NCAST is to organize, 
sponsor, and participate in research in computer science, archival 
science, and related technologies capable of improving the lifecycle 
management of records. 

In support of this responsibility, NCAST has both planned and 
completed collaborative research agreements with partners that include 
federal organizations and consortia, industry, and academia, including 
the National Science Foundation. For example, NCAST has worked with 
the Records Management Services Working Group of the Object Management 
Group (OMG), an international, open membership, not-for-profit 
standards-setting consortium of the computer industry and other 
information technology organizations, on the creation of new software 
specifications for records management.[Footnote 72] The working group 
identified and documented key requirements for records management 
functionality in systems that manage electronic records. NCAST is also 
a member of the Networking and Information Technology Research and 
Development Subcommittee of the National Science and Technology 
Council's Committee on Technology.[Footnote 73] This organization is a 
collaborative effort of more than a dozen federal research and 
development agencies that fund research in advanced information 
technologies such as computing, networking, and software. 

Examples of other collaboration efforts related to this strategy 
include two other groups. One of these is the NARA-chaired Advisory 
Committee on the Electronic Records Archives. According to its 
charter, this committee brings together experts from many different 
fields to make recommendations to the Archivist on development of ERA, 
and its membership includes experts from private organizations with an 
interest in records management, members of academia, researchers, and 
state officials with responsibility for electronic records. NARA also 
established the Federal Records Council to provide advice and support 
from other federal agencies to the Archivist on all aspects of records 
management, with special emphasis on the management of electronic 
records. Membership on the council, as stated in its charter, includes 
representatives from OMB and GSA, officials from cabinet-level 
departments, and representatives from communities such as science, 
intelligence, and the federal court system. Several other 
organizations outside of these groups have also sent members to 
Federal Records Council meetings. Members are departmental records 
officers and officials from other divisions with records management 
responsibilities, such as information technology, information security 
and privacy, and Web content. According to its charter, the council 
contributes strategic advice and support to the Archivist in issuing 
records management guidance, and provides a mechanism for agencies to 
work together to identify strategies and best practices for electronic 
information and records issues. 

In one instance (the second strategic goal, involving the accessioning 
and processing of records), NARA did not set a specific strategy 
related to collaboration. However, in discussing this goal, the 
strategic plan refers to seeking out and developing partnerships to 
assist in improving work processes to deal with a backlog of holdings 
that had been accessioned, or legally transferred to NARA's 
possession, but not yet processed. (Processing involves such steps as 
flagging records based on classification, providing enhanced 
descriptions of the content of the records, and making records 
available to the public.) In support of this goal, NARA has 
established, for example, a working agreement with a private company 
through which the company would provide metadata for digitized NARA 
information according to the agency's standards. According to an 
official, having these metadata would provide the agency with more 
information about the content of the records, which assists in their 
processing. 

Table 9 summarizes NARA's collaborative efforts related to its 
strategic goals and provides examples. 

Table 9: Collaborative Efforts Related to NARA's Strategic Goals: 

Strategic goal short title: The nation's record keeper; 
Strategy: Work with industry and academic experts to develop automated 
records management solutions; 
Effort: Begun; 
Examples: For this recently established goal (2009), NARA is beginning 
to explore approaches to automatic classification of records by type, 
but no collaborative partners have yet been identified. 

Strategic goal short title: Preserve and process; 
Strategy: (No specific collaboration strategy); 
Effort: Established; 
Examples: In an agreement with a private company, NARA receives 
metadata for digitized data. 

Strategic goal short title: Electronic records; 
Strategy: Partner with agencies, research institutions, and private 
industry to develop, implement, manage, and promote NARA's electronic 
records program; 
Effort: Established; 
Examples: NARA chairs the Federal Records Council, which gives 
strategic advice to the Archivist on issuing guidance and best 
practices for electronic information and records issues. 

Strategic goal short title: Access; 
Strategy: Establish partnerships to facilitate the availability of 
NARA holdings over the Internet; 
Effort: Established; 
Examples: By agreements with Internet companies such as Facebook and 
YouTube, NARA provides information to the public in diverse formats. 

Strategic goal short title: Civic literacy; 
Strategy: Partner with industry, national and international 
institutions, and affiliated archives to develop cooperative 
initiatives that showcase NARA holdings, promote civic and historical 
literacy, and highlight the importance of records; 
Effort: Established; 
Examples: NARA partners include: 
* National History Day, a nonprofit education organization that 
provides programs to engage middle and high school students in the 
study of history and; 
* Federal Geographic Data Committee, a federal interagency committee 
that promotes the coordinated development, use, sharing, and 
dissemination of geospatial data. 

Strategic goal short title: Infrastructure; 
Strategy: Expand partnerships with the professional communities who 
share NARA's goals and mission; 
Effort: Established; 
Examples: Under a cooperative agreement with the Council of State 
Archives, NARA has developed such projects as templates for records-
related emergency preparedness and marketing campaigns on the 
importance of records. 

Strategic goal short title: Infrastructure; 
Strategy: Continue to partner with the private foundations that 
support the National Archives and the presidential libraries to 
increase customers and produce quality products and services of 
interest to the public; 
Effort: Established; 
Examples: NARA has an agreement with the Foundation for the National 
Archives to assist in providing monetary support for NARA's programs 
and activities. 

Source: GAO analysis of NARA data. 

[End of table] 

NARA's Open Government Plan describes further collaborative 
initiatives in addition to these. Issued in response to the Open 
Government Directive,[Footnote 74] NARA's Open Government Plan 
describes its efforts aimed at increasing transparency, participation, 
and collaboration in government. Among these is a collaboration with 
the Department of Justice on the development of a dashboard that would 
provide information on agencies' performance in fulfilling Freedom of 
Information Act requests. Another is collaborating with academic law 
and policy groups, such as the Legal Information Institute at Cornell 
University and the Center for Innovative Technology Policy at 
Princeton University. 

Furthermore, in accordance with the open government principles of 
transparency, participation, and collaboration, NARA has established 
new collaborative efforts with the public. For example, according to 
its Open Government Plan, NARA used Ideascale, a commercial 
collaboration platform, to gather perspectives from the public on the 
content of the plan. It has also established blogs and a wiki to 
further collaboration both with the public and other agencies. Its 
NARAtions blog[Footnote 75] and its Our Archives wiki[Footnote 76] are 
addressed to the public and research community that uses its archival 
holdings, both providing information and soliciting input. Its Records 
Express blog[Footnote 77] shares information and solicits comment from 
the federal records management community. 

Conclusions: 

NARA has taken steps to expand its oversight activities and improve 
their effectiveness. Although it cannot by itself ensure that agencies 
are managing records appropriately (agencies control and are 
responsible for their own records), NARA can use its oversight 
activities to help determine where records management improvements are 
most needed and improve its ability to influence agencies to give more 
priority to records management programs. This will require that it 
continue to build and improve its oversight activities, including 
studies, surveys, inspections, and reporting. As NARA continues to 
refine its approach to oversight, it will be important for it to 
consider how to validate self-assessment data (for example, by doing 
followup interviews) and how to strategically plan inspections to 
maximize their value as oversight tools, by, for example, defining key 
practices and inspecting these at multiple sites. Further, it will 
also be important going forward for NARA to assess the risk that its 
capacity to process and approve schedules may not be sufficient to 
meet the demand. 

As an agency with a broad mission, NARA faces numerous challenges, for 
which its strengths in seeking collaborative opportunities should be 
helpful. Further, NARA's organizational responsibilities are generally 
aligned with its strategic plan, and it has developed a human capital 
strategic plan that, if implemented effectively, would give NARA the 
capability to strategically manage its human capital, as called for in 
our strategic human capital framework. However, there are 
opportunities for improvement. For a few specific strategies, NARA has 
not yet established clear lines and assignments of responsibility. In 
addition, the lack of adequate enterprisewide risk management leaves 
the agency vulnerable to a variety of risks that may not be foreseen 
or mitigated. Further, until NARA has implemented the capability to 
manage its human capital strategically, the risk remains that it will 
not have the staff with the skills needed to meet present and future 
mission needs. 

Recommendations for Executive Action: 

To help NARA improve its management and oversight capabilities, we are 
recommending that the Archivist of the United States take the 
following six actions: 

* To help ensure that its future assessments of the status of 
governmentwide and agency records management are accurate, develop 
additional means to validate the self-reported data in its surveys. 

* To ensure that its inspections program helps provide a comprehensive 
view of federal records management and greater impetus for agency 
improvement, develop a plan, with milestones, that provides for 
systematically and strategically targeting inspections to maximize 
their value as oversight tools. 

* To help ensure that it can manage the backlog in the scheduling 
process, assess the risk that it will be unable to keep up with 
schedules submitted and develop plans to mitigate that risk, if 
indicated. 

* To ensure that its organization and governance reflect its strategic 
goals and strategies, ensure that all the specific strategies in its 
strategic plan have clear lines and assignments of responsibility. 

* To ensure that NARA's senior staff and decision makers can 
appropriately and quickly assess threats and vulnerabilities stemming 
from enterprise risks, develop and assign responsibility and resources 
for an enterprisewide risk management capability that allows it to 
monitor its internal and external environments continuously and 
systematically. 

* To ensure that it has the appropriate skills and staff to meet 
present and future needs, give priority to completing its skills, 
needs, and gap analyses and developing a plan to fill those gaps. 

Agency Comments and Our Evaluation: 

We received written comments on a draft of this report from the 
Archivist of the United States. In these comments (reproduced in 
appendix II), NARA concurred with the six recommendations in the 
report. The Archivist stated that to address them, NARA plans to (1) 
develop and implement additional means to validate self-reported data 
from self-assessment surveys in fiscal year 2011, (2) develop a plan 
for systematically and strategically targeting inspections to maximize 
their value, (3) conduct a study of the risks associated with the 
backlog in its records scheduling process, and develop mitigation 
plans, (4) review the current strategic plan to make sure it can tie 
strategies to specific actions and targets, (5) roll out an 
enterprisewide internal controls program that uses risk assessment as 
an integral part of managing and monitoring internal controls, and (6) 
consider using an existing contract to draw in additional resources to 
assist NARA with completing its competency modeling initiative. 

The agency also supplied technical comments, which we have 
incorporated as appropriate in the final report. 

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
from the date of this letter. At that time, we will send copies of the 
report to interested congressional committees, the Archivist of the 
United States, and other interested parties. In addition, the report 
will be available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have questions about this report, please contact 
me at (202) 512-6304 or melvinv@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. Key contributors to this report are 
listed in appendix III. 

Sincerely, 

Signed by: 

Valerie C. Melvin: 
Director, Information Management and Human Capital Issues: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to (1) assess the National Archives and Records 
Administration's (NARA) effectiveness in overseeing the governmentwide 
management of records, including commenting on its capacity to 
identify risk of unlawful destruction of federal records; (2) describe 
its ability to preserve permanent records; and (3) assess its 
policies, procedures, and plans supporting key management and 
oversight capabilities: governance, human capital, and collaboration. 

For all of our objectives, we reviewed NARA documentation of its 
records management and preservation activities, interviewed agency 
officials, and reviewed prior reports by us and others. 

We reached out to the federal records management community to obtain 
information on several issues. We obtained views of selected federal 
government records managers by contacting records officials at several 
components of the Department of Defense (DOD) and through an online 
survey of members of the Federal Information and Records Managers 
Council (FIRM), an organization of federal records managers. 

We also convened a panel of experts to obtain information about 
records management challenges and best practices and NARA's oversight 
of federal records management programs. We worked with the National 
Academy of Sciences to choose a diverse group of panel members. The 
method for this was an iterative discussion with representatives of 
the Computer Science and Telecommunications Board at the National 
Academy of Sciences to determine which experts had expertise in areas 
most applicable to our objectives. The final panel included several 
former NARA employees, representatives of federal agencies that deal 
directly with NARA, and records management experts from the private 
sector and academia. The panel also included an expert in electronic 
records management, as well as one from the Smithsonian, the mission 
of which is similar to NARA's in terms of records preservation. 

To assess NARA's effectiveness in overseeing governmentwide records 
management we examined its use of the activities defined in 44 C.F.R. 
29: surveys, studies, inspections, and reporting. We obtained input 
from the expert panel, from records managers at DOD, and from our 
survey of FIRM members. We also examined NARA's process for approving 
records schedules and compared the numbers of schedules it has 
approved in recent years with estimates of the numbers of outstanding 
records series and systems. To comment on NARA's capacity to identify 
risk of unlawful destruction of federal records, we reviewed 
applicable laws, reviewed the results of the agency self-assessment 
survey, and met with NARA records management staff to identify risk 
factors. 

To describe NARA's ability to preserve permanent records, we met with 
NARA preservation staff and obtained input from the expert panel. We 
reviewed and assessed the reliability of NARA's survey of its 
preservation needs and its backlog, and we analyzed its ability to 
process its backlog. To assess NARA's ability to preserve electronic 
records, we reviewed external research and standards related to 
electronic records issues, interviewed staff involved in development 
of the Electronic Records Archives (ERA), and drew on our previous 
reports about the status of the ERA development process. 

To assess its policies, procedures, and plans supporting key 
management and oversight capabilities (governance, human capital, and 
collaboration), we did the following: 

* We assessed NARA documents relating to governance, including 
strategic planning and policy documents, against requirements of the 
Government Performance and Results Act (GPRA) and our risk management 
framework. To assess whether NARA organization and performance 
measures were aligned with its strategic plans, we examined NARA's 
directive that assigns responsibilities, as well as charters of 
temporary task forces, to determine whether lines of responsibility 
were clearly delineated for specific strategies in the strategic 
plan.[Footnote 78] We compared NARA's risk management activities 
against GPRA requirements and our risk management framework. 

* We evaluated NARA's human capital management capabilities and its 
Human Capital Strategic Plan against our strategic human capital 
framework.[Footnote 79] We interviewed the Director, Human Resources 
Services Division, and the Director, Staff Development Services, and 
other officials. To assess NARA's progress in implementing needed 
strategic human capital capabilities, we reviewed progress in 
implementing its Strategic Human Capital Plan against the plan's 
milestones. We also analyzed NARA's hiring process against Office of 
Personnel Management criteria, and examined the effects of reported 
recent improvements in the hiring process. 

* We evaluated NARA's collaboration capabilities by interviewing 
policy and planning staff, and analyzing agency policies and 
procedures related to collaboration. We obtained a list of NARA 
collaborative projects and examined whether collaborative activities 
specified in the strategic plan were being carried out. 

We conducted this performance audit from October 2009 to October 2010 
in the Washington, D.C., metropolitan area in accordance with 
generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings 
and conclusions based on our audit objectives. We believe that the 
evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the National Archives and Records 
Administration: 

National Archives And Records Administration: 
8601 Adelphi Road: 
College Park, MD 20740-6001: 
[hyperlink, http://www.archives.gov] 

Via messenger: 

September 27, 2010: 

Valerie C. Melvin: 
Director, Information Management and Human Capital Issues: 
United States Government Accountability Office: 
44 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Melvin, 

Thank you for the opportunity to review and comment on the draft 
report entitled National Archives and Records Administration: 
Oversight and Management Improvements Initiated, but More Action 
Needed. We are pleased to note the positive recognition of our efforts 
to date in several oversight and management areas. We also agree that 
more action is needed, and concur with the six recommendations in this 
report. 

Many changes are underway at NARA, including a staff reorganization 
that will help us more effectively address the challenges we face. I 
believe strongly in the talent we have at NARA and I know that the 
report recommendations are achievable. The following outlines the 
report's recommendations and the actions we will take to address them. 
We will provide semi-annual updates on our progress. 

(1) To help ensure that its future assessments of the status of 
government-wide and agency records management are accurate, (the 
Archivist) should develop additional means to validate the self-
reported data in its surveys. 

NARA will develop and implement additional means to validate self-
reported data from self-assessment surveys in FY 2011. Each year, 
during the first and second quarters, NARA will re-evaluate its 
validation approaches and methodologies, implementing changes as 
needed to improve the efficacy and usefulness of the results for NARA 
and the agencies. 

(2) To ensure that its inspections program helps provide a 
comprehensive view of Federal records management and a greater impetus 
for agency improvement, (the Archivist) should develop a plan with 
milestones, that provides for systematically and strategically 
targeting inspections to maximize their value as oversight tools. 

In our response to GAO-08-742, Federal Records: National Archives and 
Selected Agencies Need to Strengthen E-mail Management, we stated that 
the results of our annual Federal records management self-assessments 
will help inform both studies and inspections. In FY 2011 NARA will 
develop a plan for how to develop annual targeted inspections that 
includes this concept and others as appropriate. We will pilot the 
approach prior to implementation in FY 2013. In the meantime, NARA 
will continue to conduct the inspections that were started or will 
start in FY 2011. 

(3) To help ensure that it can manage the backlog in the scheduling 
process; (the Archivist) should assess the risk that it will be unable 
to keep up with schedules submitted and develop plans to mitigate that 
risk, if indicated. 

NARA will conduct a study of the risks associated with this backlog 
and develop mitigation plans. The study will be completed by the end 
of the 2nd quarter, FY 2012. 

(4) To ensure that its organization and governance reflect its 
strategic goals and strategies, (the Archivist) should ensure that all 
the specific strategies in its strategic plan have clear lines and 
assignments of responsibility. 

We will review the current strategic plan for ownership of specific 
strategies. While most have owners, a few do not. For the majority of 
strategies that do have owners, it is probably a good idea to remind 
owners and ask them to make sure we can tie these strategies to 
specific actions and targets currently or soon to be underway. 

(5) To ensure that NARA's senior staff and decision makers can 
appropriately and quickly assess threats and vulnerabilities stemming 
from enterprise wide risks, (the Archivist) should develop and assign 
responsibility and resources for an enterprise wide risk management 
capability that allows it to monitor its internal and external 
environments continuously and systematically. 

As part of the reorganization proposed by our Transformation Task 
Force, internal controls and risk management are being given more 
prominence and credibility in a Performance and Accountability staff 
office. Through this office, we will continue our work to roll out an 
enterprise-wide internal controls program that ensures responsibility 
and accountability for NARA's lines of business, and uses risk 
assessment as an integral part of managing and monitoring internal 
controls. We believe this work will embed an awareness of risk factors 
throughout the organization as part of an ongoing, repetitive process. 
I will assign a NARA Risk Officer to manage this process, and who will 
raise risks identified to our Leadership Guidance Team (LGT) or 
similar executive leadership group. As envisioned in OMB Circular A-
123, this executive body will participate in assessing and monitoring 
internal control deficiencies and will be involved in identifying and 
ensuring correction of systemic weaknesses. 

(6) To ensure that it has the appropriate skills and staff to meet 
present and future needs, (the Archivist) should give priority to 
completing its skills, needs, and gap analyses and developing a plan 
to fill those gaps. 

Earlier this year, I directed the formation of an Archivist's Task 
Force on Agency Transformation to look at possible improvements to the 
agency. One of the improvements recommended by the task force was the 
creation of a separate Human Capital Office directed by a Chief Human 
Capital Officer (CHCO) position that would report directly to the 
Archivist and the Deputy Archivist on human capital matters. This 
office will bring together all of NARA' s human capital programs and 
activities under one umbrella, allowing NARA to take a comprehensive 
and cohesive approach to human capital management throughout the 
agency. The CHCO will be an integral part of the Executive Leadership 
Team. 

As noted in the audit report, NARA has had to divert staff resources 
from implementing certain strategic human capital initiatives to 
respond to new mandates from the Office of Personnel Management (OPM), 
such as the OPM 2009 Hiring Reform and the May 2010 Presidential 
Hiring Reform Initiative. While the result of diverting these staff 
resources has lead to improvements in hiring as noted in the report 
(specifically the reduction in the average time to fill a position 
from 163 days to 126.5 days), we believe that these new mandates will 
continue to require additional staff time as we work towards the OPM 
goal of 80 days to fill a position. As such, we will consider using an 
existing contract to draw in additional resources to assist NARA with 
completing our competency modeling initiative so that we can move 
forward with performing the gap analyses to plan future human capital 
needs. 

If you have questions regarding this information, please contact Mary 
Drak by email at mary.drak@nara.gov or by phone at 301-837-1668. 

Signed by: 

David S. Ferriero: 
Archivist of the United States: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Valerie C. Melvin, (202) 512-6304 or melvinv@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, key contributors to this 
report were Barbara Collier (Assistant Director), Shaun Byrnes, Kami 
Corbett, Neil Doherty, Rebecca Eyler, Jason Kirwan, Lee McCracken, 
Glenn Spiegel, and Walter Vance. 

[End of section] 

Footnotes 

[1] The Government Performance and Results Act of 1993, Pub. L. No. 
103-62, 107 Stat. 285 (Aug. 3, 1993), among other things, requires 
agencies to prepare strategic plans and annual performance plans that 
articulate goals for the upcoming fiscal year that are aligned with 
their long-term strategic goals. 

[2] GAO, A Model of Strategic Human Capital Management, [hyperlink, 
http://www.gao.gov/products/GAO-02-373SP] (Washington, D.C.: Mar. 15, 
2002). 

[3] NARA's work is also supported by contractors and volunteers. 

[4] The National Archives Trust Fund and Presidential Library Trust 
Funds budget authority includes revenues generated from the sale of 
publications, museum shop sales, paper reproductions, audiovisual 
reproductions, library admissions, educational conferences, and 
interest income. Expenditures are made for the cost of museum shop 
inventory, personnel, operational and financial systems, equipment, 
and reproduction supplies. The National Archives Trust Fund and 
Presidential Library Trust Funds earned revenue of $18 million in 
fiscal year 2009. 

[5] The Gift Fund's budget authority includes donations to NARA and 
interest earned on those gifts and endowments. It was established to 
administer incoming gifts and bequests for the benefit of, or in 
connection with, the agency's archival and records activities. 
Expenditures are made for various programs, including historical 
research, conferences, archival and cultural events, and publications. 
In fiscal year 2009, the gift fund received donations of $2 million. 

[6] The Revolving Fund's budget authority includes revenue generated 
from the temporary federal agency records stored in NARA service 
facilities. It provides storage, transfer, reference, refile, and 
disposal services for a standard fee. In fiscal year 2009, the 
Revolving Fund earned revenue of $152 million. 

[7] The various presidential libraries are also supported by separate 
gift funds, endowments, and presidential library foundations. 

[8] Relevant NARA regulations implementing the Federal Records Act are 
found at 36 C.F.R. §§ 1220-1239. 

[9] These shared responsibilities are due in part to the origins of 
NARA. The 1984 National Archives and Records Administration Act, Pub. 
L. No. 98-497, 98 Stat. 2280 (Oct. 19, 1984), transferred the 
functions of GSA's National Archives and Records Service to the newly 
created NARA. 

[10] See 44 U.S.C. § 3504. 

[11] See 44 U.S.C. § 3602. 

[12] 36 C.F.R. § 1230.3. 

[13] 36 C.F.R. § 1230.10. 

[14] A terabyte is about 1 trillion bytes, or 1000 gigabytes. 

[15] GAO, Information Management: Challenges in Managing and 
Preserving Electronic Records, [hyperlink, 
http://www.gao.gov/products/GAO-02-586] (Washington, D.C.: June 17, 
2002); Records Management: Planning for the Electronic Records 
Archives Has Improved, [hyperlink, 
http://www.gao.gov/products/GAO-04-927] (Washington, D.C.: Sept. 23, 
2004); Information Management: Acquisition of the Electronic Records 
Archives Is Progressing, [hyperlink, http://www.gao.gov/products/GAO-
05-802] (Washington, D.C.; July 15, 2005); Electronic Records 
Archives: The National Archives and Records Administration's Fiscal 
Year 2006 Expenditure Plan, [hyperlink, 
http://www.gao.gov/products/GAO-06-906] (Washington, D.C.: Aug. 18, 
2006); Information Management: The National Archives and Records 
Administration's Fiscal Year 2007 Expenditure Plan, [hyperlink, 
http://www.gao.gov/products/GAO-07-987] (Washington, D.C.: July 27, 
2007); Information Management: Challenges in Implementing an 
Electronic Records Archive, [hyperlink, 
http://www.gao.gov/products/GAO-08-738T] (Washington, D.C.: May 14, 
2008); and National Archives: Progress and Risks in Implementing its 
Electronic Records Archive Initiative, [hyperlink, 
http://www.gao.gov/products/GAO-10-222T] (Washington, D.C.: Nov. 5, 
2009). 

[16] GAO, Electronic Records Archive: Status Update on the National 
Archives and Records Administration's Fiscal Year 2010 Expenditure 
Plan, [hyperlink, http://www.gao.gov/products/GAO-10-657] (Washington, 
D.C.: June 11, 2010). 

[17] GAO, National Archives: Preserving Electronic Records in an Era 
of Rapidly Changing Technology, [hyperlink, 
http://www.gao.gov/products/GGD-99-94] (Washington, D.C.: July 19, 
1999). 

[18] In 2001, a NARA-sponsored study was released reporting on both a 
recordkeeping study performed by SRA International and a series of 
records system analyses performed by NARA staff. 

[19] [hyperlink, http://www.gao.gov/products/GAO-02-586]. 

[20] [hyperlink, http://www.gao.gov/products/GAO-06-906]. 

[21] GAO, Federal Records: National Archives and Selected Agencies 
Need to Strengthen E-Mail Management, [hyperlink, 
http://www.gao.gov/products/GAO-08-742] (Washington, D.C.: June 13, 
2008). 

[22] GAO, Information Management: The Challenges of Managing 
Electronic Records, [hyperlink, 
http://www.gao.gov/products/GAO-10-838T] (Washington, D.C.: June 17, 
2010). 

[23] In our recent testimony, [hyperlink, 
http://www.gao.gov/products/GAO-10-838T], we describe a number of 
challenges facing federal records management. 

[24] In particular, the reports are to include evaluations of 
responses by agencies to any recommendations resulting from 
inspections or studies that NARA conducts and, to the extent 
practicable, estimates of costs to the government if agencies do not 
implement such recommendations. 

[25] [hyperlink, http://www.gao.gov/products/GAO-08-742]. 

[26] According to NARA officials, scheduled records are less at risk 
because scheduling presupposes that an agency has key controls in 
place, such as an inventory, file plan, and records management 
directive. Other indicators of risk include out-of-date schedules, 
records created by an entity that is going out of business; records 
created by multiple agencies, and lack of knowledgeable leadership for 
a records management program. 

[27] NARA, Records Management Self-Assessment 2009: An Assessment of 
Records Management Programs in the Federal Government (April 2010). 

[28] NARA assessed risk by calculating a weighted score based on 
agencies' responses to the 34 survey questions. Scores above 90 of 100 
possible points are considered low risk, 60 to 89 are moderate risk, 
and below 60 are high risk. 

[29] AOTUS blog, [hyperlink, http://blogs.archives.gov/aotus/?p=186] 
(April 20, 2010). 

[30] NARA requested these reports in October 2008, April 2009, and 
August 2009. 

[31] NARA, NARA's Electronic Records Project, Summary Report FY 2005-
FY 2009 (June 15, 2010). 

[32] [hyperlink, http://www.gao.gov/products/GAO-08-742]. 

[33] Agencies regulated under 36 C.F.R. Chapter XII, Subchapter B. 

[34] 36 C.F.R. § 1220.34(a) does not specify at what level agencies 
must designate records officers. 

[35] Appraisal archivists are members of NARA's records management 
staff who perform appraisals of agency records as part of the 
scheduling process. Because appraisal archivists are generally 
assigned to specific agencies, they may have insight into these 
agencies' records management programs. 

[36] NARA, NARA's Strategic Directions for Federal Records Management 
(July 31, 2003). 

[37] NARA, Strategic Directions: Inspections and Studies of Records 
Management in Federal Agencies (October 2003). 

[38] In 2008 we reported that NARA had conducted or sponsored six 
records management studies since 2003 [hyperlink, 
http://www.gao.gov/products/GAO-08-742]. 

[39] NARA Bulletin 2010-03, Flexible Scheduling (May 3, 2010). 

[40] This system captures e-mail and makes it searchable, but it is 
not a records management system as it lacks required recordkeeping 
features. 

[41] NARA had suspended this type of inspection in 2000, because, 
according to an agency official, it considered the process time- 
consuming, resource intensive, and difficult to implement. 

[42] 36 C.F.R. Part 1239. 

[43] According to NARA officials, the choice of inspections for fiscal 
year 2010 (see table 4) was not based on the results of the first self-
assessment, which became available in April 2010. 

[44] This enforcement capability does not extend to how agencies 
implement the schedules in their day-to-day activities. Agencies 
control and are responsible for their records. 

[45] Section 207(e) of the E-Government Act of 2002 directs the 
Archivist to issue policies requiring agencies to adopt policies and 
procedures to ensure that records management requirements (chapters 
21, 25, 27, 29, and 31 of title 44, U.S. Code) are applied effectively 
and comprehensively to government information on the Internet and to 
other electronic records. It also requires the Archivist to impose 
timetables for agencies to implement policies, procedures, and 
technologies. 

[46] NARA Bulletin 2006-02, NARA Guidance for Implementing Section 
207(e) of the E-Government Act of 2002, dated December 15, 2005, 
formally established a governmentwide deadline of September 30, 2009, 
for agencies to submit records schedules to NARA for all their 
electronic records existing as of December 17, 2005. This requirement 
was reiterated in NARA Bulletin 2008-03 (Mar. 6, 2008). 

[47] NARA requested these reports in October 2008, April 2009, and 
August 2009. 

[48] NARA Bulletin 2010-02, Continuing Agency Responsibilities for 
Scheduling Electronic Records (Feb. 5, 2010). 

[49] NARA, NARA's Electronic Records Project, Summary Report FY 2005-
FY 2009 (June 15, 2010). 

[50] In contrast to preservation, conservation attempts to preserve 
records in their original format. Conservators examine records and 
assess their condition and the materials of which they are made. 
Conservators then recommend remedial treatments to arrest 
deterioration or to improve condition. 

[51] The baseline for this number was developed based on an extensive 
sample survey conducted in 2004-2005. Since the initial baseline was 
established, as new accessions are received, the numbers needing 
preservation are initially estimated based on a default value obtained 
from the survey; these estimated values are then adjusted as the 
records are actually inspected. As preservation actions are taken, the 
numbers are reduced. 

[52] 2009 Performance and Accountability Report. 

[53] Other functional areas include ingest, records management, 
archival storage, and dissemination. 

[54] NARA defines transformation as "reformatting or otherwise 
changing the way an electronic record is digitally encoded in order to 
reduce or eliminate dependencies on specific hardware or software, 
while preserving authenticity." 

[55] According to NARA, characteristics of sustainable formats include 
generic or open formats, such as plain ASCII and XML, which do not 
require any particular hardware or software; formats with published or 
open documentation; and formats that are ubiquitous in the 
marketplace, like the Microsoft Office products or PDF files. Further, 
sustainable formats are self-describing, meaning that they have 
embedded within them the metadata necessary to interpret the records. 

[56] [hyperlink, http://www.gao.gov/products/GAO-10-657]. 

[57] Risk factors considered by OMB in listing projects included 
significant cost or schedule variance, performance targets or mission 
objectives have not been met, frequent rebaselines, and lack of 
essential executive sponsorship/leadership. 

[58] As mentioned earlier, we recommended in GAO-10-657 that NARA 
ensure that ERA's requirements are managed using a disciplined process 
that ensures that requirements are traceable throughout the project's 
life cycle and are kept current. 

[59] Earned value management is a technique that integrates the 
technical, cost, and schedule parameters of a development contract and 
measures progress against them. We reported in GAO-10-657 that NARA 
had partially implemented our recommendation: it had developed but not 
fully implemented an action plan to improve its earned value processes. 

[60] GAO, Legal Services Corporation: Some Progress Made in Addressing 
Governance and Accountability Weaknesses, but Challenges Remain, 
[hyperlink, http://www.gao.gov/products/GAO-10-194T] (Washington, 
D.C.: Oct. 27, 2009). 

[61] NARA, Preserving the Past to Protect the Future: The Strategic 
Plan of the National Archives and Records Administration 2006-2016, 
revised 2009. 

[62] GAO, Results-Oriented Cultures: Implementation Steps to Assist 
Mergers and Organizational Transformations, [hyperlink, 
http://www.gao.gov/products/GAO-03-669] (Washington, D.C.: July 2, 
2003). 

[63] GAO, Legal Services Corporation: Governance and Accountability 
Practices Need to Be Modernized and Strengthened, [hyperlink, 
http://www.gao.gov/products/GAO-07-993] (Washington, D.C.: Aug. 15, 
2007). 

[64] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999) and Executive Guide: Effectively 
Implementing the Government Performance and Results Act, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-96-118] (Washington, D.C.: June 
1996). 

[65] GAO, Risk Management: Further Refinements Needed to Assess Risks 
and Prioritize Protective Measures at Ports and Other Critical 
Infrastructure, [hyperlink, http://www.gao.gov/products/GAO-06-91] 
(Washington, D.C.: Dec. 15, 2005). 

[66] NARA senior staff who serve on the Lifecycle Guidance Team 
include the heads of Washington Records Services, Regional Records 
Services, Presidential Libraries, and Information Services. 

[67] GAO, Human Capital: Taking Steps to Meet Current and Emerging 
Human Capital Challenges, [hyperlink, 
http://www.gao.gov/products/GAO-01-965T] (Washington, D.C.: July 17, 
2001). 

[68] GAO, Human Capital: Sustained Attention to Strategic Human 
Capital Management Is Needed, [hyperlink, 
http://www.gao.gov/products/GAO-09-632T] (Washington, D.C.: Apr. 22, 
2009). 

[69] GAO, Information Technology: FBI Has Largely Staffed Key 
Modernization Program, but Strategic Approach to Managing Program's 
Human Capital Is Needed, [hyperlink, 
http://www.gao.gov/products/GAO-07-19] (Washington, D.C.: Oct. 16, 
2006). 

[70] OPM's 2009 Hiring Reform required agencies to identify barriers 
to timely and effective hiring by September 2009 and develop action 
plans for addressing these barriers by December 2009. 

[71] USA Staffing automatically generates vacancy announcements; posts 
vacancy announcements on USAJOBS; accepts applications via Internet, 
phone, or fax; analyzes applicant competencies and qualifications; 
rates and ranks job applicants; covers all available hiring 
flexibilities; produces and updates certificates; notifies applicants; 
manages applicant records; and meets all regulatory requirements and 
can be adapted for agency-specific procedures. 

[72] The Records Management Services effort aims to implement 
functional requirements previously developed for records management 
services components to be included in the Federal Enterprise 
Architecture component repository. 

[73] The National Science and Technology Council is part of Office of 
Science and Technology Policy in the Executive Office of the President. 

[74] OMB, Open Government Directive, M-10-06 (Dec. 8, 2009). 

[75] blogs.archives.gov/online-public-access. 

[76] [hypertlink, http://www.ourarchives.wikispaces.net]. 

[77] blogs.archives.gov/records-express. 

[78] We looked at 21 specific strategies, excluding others that were 
not within the scope of our engagement. 

[79] GAO, A Model of Strategic Human Capital Management, [hyperlink, 
http://www.gao.gov/products/GAO-02-373SP] (Washington, D.C.: Mar. 15, 
2002). 

[End of section] 

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