Information Management: Additional Actions Are Needed to Meet Requirements of the Managing Government Records Directive
Highlights
What GAO Found
The 24 federal agencies took actions toward implementing each of the seven requirements set forth in the National Archives and Records Administration (NARA) and Office of Management and Budget (OMB) directive on managing government records (see table).
Agency Implementation of Managing Government Directive Requirements
|
Directive area |
Due date |
Number of agencies implementing requirement |
|
Designate senior agency officials to oversee records management activities at assistant secretary level |
November 15, 2012 |
22 of 24 |
|
Report on progress to manage permanent and temporary e-mail records in electronic format |
August 24, 2013a |
23 of 24 |
|
Develop and begin to implement plans to manage all permanent records in an electronic format |
December 31, 2013 |
23 of 24 |
|
Identify for transfer and report permanent records in existence for more than 30 years |
December 31, 2013 |
21 of 24 |
|
Identify all unscheduled records that have not been properly scheduled |
December 31, 2013 |
20 of 24 |
|
Obtain NARA certificate for records management training |
December 31, 2014 |
22 of 24 |
|
Establish records management training for all staff |
December 31, 2014 |
22 of 24 |
Source: GAO analysis of data provided by 24 major agencies. | GAO-15-339
aNARA subsequently changed the reporting deadline to December 31, 2013.
However, certain requirements were not fully met by 5 of the agencies because these agencies were either still working on addressing the requirement, or did not view the requirement as mandatory. For example, while all 24 agencies designated a senior official to oversee records management, 2 did not designate the official at the assistant secretary level, and 1 did not reaffirm the official by the specified deadline. Further, at 2 agencies, records management officers did not obtain the NARA training certificate or had not been granted an exemption. These agencies expect to complete their training by the end of fiscal year 2015.
The Office of Personnel Management (OPM), OMB, and NARA took steps to implement 11 required oversight actions, although not all actions had been completed. For example, OPM finalized an occupational series to elevate records management roles, responsibilities, and skill sets for agency records professionals. In addition, OMB was in the process of updating its Circular A-130 to include records management requirements for agencies when moving to cloud-based services or storage solutions. The agency expects to release the updated circular by December 2015. Lastly, NARA, in consultation with other stakeholders, produced a plan to move agencies toward greater automation of records management. However, it did not include metadata requirements in its guidance, as required. Until agencies, OMB, and NARA fully implement the directive's requirements, the federal government may be hindered in its efforts to improve performance and promote openness and accountability through the reform of records management.
Why GAO Did This Study
The federal government collects large amounts of information, increasingly in electronic form, to accomplish its missions. This greater reliance on electronic communication and information technology systems has, as a result, radically increased the information that agencies must manage. In 2012, NARA and OMB issued a directive to reform federal records management in response to a 2011 presidential memorandum on managing government records. The directive requires federal agencies, NARA, OMB, and OPM to take actions toward reforming records management policies and practices.
GAO was requested to evaluate federal agencies' implementation of the directive. GAO's objectives were to (1) assess the extent to which federal agencies have taken the actions called for in the directive and (2) determine the extent to which OPM, OMB, and NARA have taken actions called for in the directive. To do this, GAO reviewed policies, guidance, and other documentation of actions taken through December 31, 2014, by 24 selected federal agencies, NARA, and OMB, and interviewed the agencies' records management officials.
Recommendations
GAO is making 10 recommendations to 5 federal agencies and NARA to ensure records management directive requirements on designating senior officials and identifying, reporting, and managing records are met. In commenting on a draft of this report, the agencies and NARA generally agreed with the recommendations.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Office of Personnel Management | To help ensure that directive requirements are met, the Director of the Office of Personnel Management should ensure that the Senior Agency Official designated to oversee the agency's compliance with records management statutes and regulations is at or equivalent to the level of an assistant secretary, as required by the directive. |
In response to our recommendation, the Office of Personnel Management (OPM) designated its Chief Information Officer as the Senior Agency Official. This designation, as of July 2015, was updated on NARA's website that contains a listing of all designated Senior Agency Officials across the federal government.
|
| Department of Veterans Affairs | To help ensure that directive requirements are met, the Secretary of Veterans Affairs should designate a Senior Agency Official at or equivalent to the level of assistant secretary who has direct responsibility for ensuring that the agency complies with applicable records management statutes, regulations, and NARA policy, including being able to make adjustments to agency practices, personnel, and funding. |
In response to our recommendation, the Department of Veterans Affairs designated its Chief Information Officer, Office of Information Technology as the Senior Agency Official with responsibility for complying with applicable records management statues, regulations, and National Archives and Records Administration policy. This designation, as of May 2015, was updated on NARA's website that contains a listing of all designated Senior Agency Officials across the federal government.
|
| Department of Transportation | To help ensure that directive requirements are met, the Secretary of Transportation should identify permanent records that were in existence for 30 years or more for one remaining component and report this information to NARA. |
The Department of Transportation concurred with our recommendation and, in September 2015, took action to implement our recommendation. Specifically, the Director of the Departmental Records Management Office reported to NARA the records of the one remaining component that had completed identifying its permanent records that were in existence for 30 years or more.
|
| National Science Foundation | To help ensure that directive requirements are met, the Director of the National Science Foundation should establish a date by which the agency will complete, and then report to NARA, its plans for managing permanent records electronically. The plan should describe, among other things, how permanent electronic records are currently captured, retained, searched, and retrieved; plans to digitize permanent records currently in hard-copy format or other analog formats; plans to manage all permanent electronic records in electronic format, including how the plans will be implemented; and challenges the agency faced in achieving the requirement of managing all permanent electronic records in an electronic format. |
NSF concurred with our recommendation, and in response completed its plans for managing permanent records electronically. We verified, in March 2017, that the agency reported its plans to NARA in February 2016. The plans described the management, and digitization of permanent electronic records, including challenges the agency will face.
|
| National Science Foundation | To help ensure that directive requirements are met, the Director of the National Science Foundation should establish a date by which the agency will complete, and then report to NARA on, its progress toward managing permanent and temporary e-mail records in an electronic format, to include the agency's ability to retain e-mail records in an electronic system that supports records management and litigation requirements, including the capability to identify, retrieve, and retain the records for as long as they are needed. |
NSF concurred with our recommendation and in February 2017 we verified that NSF has taken actions in response to our recommendation. Specifically, NSF's Corrective Action Plan for Records Management, submitted to Congress, discussed the date (December 2015) by which the agency will complete, and then report to NARA on its progress toward managing permanent and temporary e-mail records in an electronic format. Additionally, NSF confirmed to NARA that it will utilize the NARA Capstone policy to manage its email records. According to NSF, the implementation of the Capstone approach will allow the agency to retain email records through an electronic system that supports records management and litigation requirements (which may include preservation-in place models), including the capability to identify, retrieve, and retain the records for as long as they are needed.
|
| National Science Foundation | To help ensure that directive requirements are met, the Director of the National Science Foundation should report to NARA on the identification of its permanent records in existence for 30 years or more, to include when no such records exist. |
NSF concurred with our recommendation, and as of February 2017, we verified that NSF identified its permanent records in existence for 30 years or more and reported this information to NARA. Specifically, NSF provided an email transmission to NARA's Chief Records Officer which stated that the agency had completed verifying and validating the accuracy of the report of permanent records identified as 30-years old or more and has determined that there are no records meeting this criterion in existence within the agency.
|
| National Science Foundation | To help ensure that directive requirements are met, the Director of the National Science Foundation should complete the identification of unscheduled records stored at agency records storage facilities. |
NSF concurred with our recommendation, and in February 2017, we verified that the agency completed the identification of its unscheduled records stored at agency records storage facilities. As a result of these actions, NSF has lowered the risk that its records would be destroyed without NARA?s awareness and approval.
|
| National Archives and Records Administration | To help ensure that directive requirements are met, the Archivist of the United States should establish a time frame and revise NARA transfer guidance for permanent electronic records to include all aspects of metadata requirements. |
The National Archives and Records Administration (NARA) concurred with this recommendation and in September 2015, the Archivist of the United States issued a bulletin to the heads of federal agencies on metadata guidance for the transfer of permanent electronic records. The bulletin defines the minimum set of metadata elements that must accompany transfers of permanent electronic records to the National Archives.
|
| National Archives and Records Administration | To help ensure that directive requirements are met, the Archivist of the United States should identify tools to assist agencies with addressing records management challenges in cooperation with the Federal Chief Information Officers Council, the Federal Records Council, and other government-wide councils that express interest. |
In response to our recommendation, the National Archives and Records Administration (NARA), in cooperation with the Federal Records Council and community of interest groups, identified tools to assist agencies with addressing records management challenges. Specifically, in May 2015, we verified that NARA, in cooperation with the Federal Records Council, had worked with community of interest groups, including the Electronic Records Management Automation Working Group and the Federal Records Officer Network, to identify and make available online, a listing of open source records management tools that could be used to support various records management functions. By doing so, NARA and the community of interest groups contributed to federal agencies' awareness regarding electronic records management tools that are available to assist them with addressing records management challenges.
|
| General Services Administration | To help ensure that directive requirements are met, the Administrator of the General Services Administration should expedite efforts to ensure that permanent records that were in existence for 30 years or more, including records stored at agency records storage facilities, are identified and reported to NARA. |
In response to our recommendation, the General Services Administration (GSA) took steps to identify and report its permanent 30-year-old records to NARA. Among other actions, GSA conducted internal requests for records that met the criteria, identified the records across the agency, and confirmed their storage and the associated points of contact. Lastly, GSA reported the 30-year-old permanent records to NARA.
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